Treasury Targets Electronics Exporters, Carriers in Miami

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Attorneys & Professionals

Heather Kabele, a partner in the Vorys Houston office and a member of the litigation group, authored an article for the Journal of Commerce titled “Treasury Targets Electronics Exporters, Carriers in Miami.” The article was about the U.S. Department of the Treasury’s Financial Crimes Enforcement Network Geographic Targeting Order (GTO) that was recently announced. The GTO is aimed at Miami, Florida electronics exporters and common carriers and requires them to report of cash or cash-equivalent transactions in excess of $3,000 until at least October 25, 2015.

The article states:

“The GTO, which FinCEN issued to approximately 700 Miami businesses on April 21, 2015, is part of FinCEN’s efforts to ramp up reporting intended to expose trade-based money laundering schemes involving drug cartels.  The Miami GTO is the third such GTO issued by FinCEN since August 2014; the other two GTO’s targeted the Fashion District in Los Angeles and California ports of entry at the U.S.-Mexico border.

All businesses that have received the Miami GTO are subject to its terms, absent special dispensation from FinCEN.  While the Miami GTO expressly references as a “Covered Business” a trade or business in the covered geographic area that “exports electronics (including cell phones)” and its agents, subsidiaries and franchisees, the order also has been deemed to extend to common carriers that transport others’ goods internationally.  It is less clear whether FinCEN intended common carriers that transport goods only domestically to be covered by the GTO.  Such businesses, as well as any business believing it received the GTO in error, should contact FinCEN to discuss that issue.”       

To read the entire article, visit the Journal of Commerce website.