In an article for AML Intelligence, Himamauli Das co-authored an analysis of how Geographic Targeting Orders (GTOs) have taken on a more central role in U.S. anti-money laundering (AML) enforcement and compliance.
In “INSIGHT: How Geographic Targeting Orders Have Taken Center Stage in the US AML Toolkit” (3 September 2026), Him and co-authors Sam Kleiner and Roberto Gonzalez examine FinCEN’s expanding use of GTOs, recent legal challenges to the authority, and the operational considerations facing institutions that may become subject to targeted reporting requirements.
The authors explain the evolution of GTOs from narrow information-gathering instruments designed to address gaps in the Bank Secrecy Act/AML framework into a more prominent mechanism for imposing additional reporting obligations on financial institutions, money services businesses, and nonfinancial trades and businesses.
The key takeaway: GTOs are now a core AML tool, and financial institutions should be prepared to adapt compliance programs quickly as new or renewed orders impose targeted obligations. At the same time, broader GTOs may face heightened legal scrutiny, and evolving payments systems may complicate how geographically focused authorities are applied in practice.
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