On April 21, 2015, the Financial Crimes Enforcement Network (FinCEN) posted an alert flagging a new Geographic Targeting Order (GTO) that was sent to roughly 700 Miami businesses. According to FinCEN’s alert, the GTO was issued “to shed light on cash transactions that may be tied to trade-based money laundering schemes.”
The GTO lowers the monetary threshold for the filing of Form 8300s by Miami-area nonfinancial trades and businesses “that export[] electronics (including cellphones).” The general rule is that a business must file a Form 8300 with the Internal Revenue Service if it receives more than $10,000 in cash from one buyer as a result of a single transaction or two or more related transactions.1 There are criminal and civil penalties for failing to file Form 8300s.2 The GTO lowers the reporting threshold to $3,000 for the covered trades and businesses for 120 days—from April 28, 2015, until Oct. 25, 2015.3
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