Bondi Blocked From Enforcing New Bar for Money Transfer Reports

US Attorney General Pam Bondi is prohibited from enforcing a directive that would flag transfers over $200 at 10 money services businesses near the southern border, a district court ruled Friday.

The Texas Association of Money Services Businesses showed that it was likely to prevail in its legal challenge of the directive and sufficiently alleged that it faces irreparable harm absent court intervention, Judge Fred Biery said in a short order. The judge, who sits on the US District Court for the Western District of Texas, granted the association’s motion for a temporary restraining order.

The restraining order is set to expire April 25 and applies only to the ten businesses that are members of the associations. The association can’t add new members, Biery said.

The association is challenging the Financial Crimes Enforcement Network’s March 11 geographic targeting order lowering the transfer threshold from $10,000 to $200 to trigger mandatory currency transaction reports. All money services businesses in 30 selected ZIP codes in California and Texas would have to file their reports with FinCEN. The order was slated to be effective from April 14 through Sept. 9.

The association argues this directive violates the Fifth Amendment and the Administrative Procedure Act. It contends that one of the businesses it represents would have to file nearly 50,000 reports per week just based on its dozens of locations in Texas, up from an average of nine reports a week.

The directive violates the APA because it flouts federal law, is contrary to the US Constitution, and was adopted without a notice-and-comment rulemaking process, the association said in its complaint. It also alleged the directive exceeds the Treasury Department’s statutory authority under the Bank Secrecy Act.

It allegedly violates the Fifth Amendment since it discriminates based on viewpoint-based or political interests, disproportionately targeting regions “leaning” to the Democratic Party while exempting similarly situated jurisdictions with “Republican-leaning” voter bases, the association said. The Texas ZIP codes affected in this order are also “overwhelmingly” concentrated in Latino counties and neighborhoods, making it racially discriminatory.

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, 4/11/25.