Bondi Again Blocked From Enforcing Money Transfer Reports Rule

US Attorney General Pam Bondi still can’t enforce a directive designed to flag transfers over $200 at 10 money services businesses near the southern border, a district court ruled Monday.

Judge Fred Biery granted The Texas Association of Money Services Businesses’ motion to preliminarily enjoin Bondi from enforcing the Financial Crimes Enforcement Network’s March geographic targeting order. The association and 10 money services businesses allege the order—which lowers the transfer threshold from $10,000 to $200 to trigger a mandatory currency transaction report—violates the Fifth Amendment and the Administrative Procedure Act.

The court finds the geographic targeting order “likely violates the Fourth Amendment of the Constitution’s Bill of Rights prohibiting unreasonable searches and seizures and that it is likely ‘arbitrary and capricious’” in violation of the APA, Biery said.

The US District Court for the Western District of Texas previously temporarily blocked Bondi from enforcing the order in April after Biery ruled the businesses showed they were likely to prevail in the suit and sufficiently alleged they faced irreparable harm absent court intervention. Biery entered a temporary restraining order, which was later extended until May 9.

The businesses contended that the order should be vacated along with any preliminary injunction, according to their May 7 reply brief. The association alleged in their complaint that the lowered threshold, which was previously $10,000, would require one of the businesses it represents to increase its weekly reports from an average of nine to nearly 50,000 just based on its dozens of locations in Texas.

The businesses say the order violates the APA since it flouts federal law, is contrary to the US Constitution, and was adopted without a notice-and-comment rulemaking process. The order also exceeds the US Treasury Department’s statutory authority under the Bank Secrecy Act. The order also violates the Fifth Amendment since it targets regions “leaning” to the Democratic Party and is “overwhelmingly” concentrated in Latino counties and neighborhoods, the complaint said.

The Law Office of Martin Golando PLLC and The Law Office of Roland Gutierrez represent the association.

The case is Texas Ass’n of Money Services Businesses v. Bondi, W.D. Tex., No. 5:25-cv-00344, 5/12/25.