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Financial Services Law Insights and Observations

FinCEN Issues Geographic Targeting Order to Combat Stolen Identity Tax Refund Fraud in South Florida

FinCEN Check Cashing

Privacy, Cyber Risk & Data Security

On July 13, FinCEN issued a Geographic Targeting Order (GTO) requiring check cashers in two South Florida counties to strengthen identification requirements for customers cashing certain Federal tax refund checks. According to FinCEN, Miami-Dade and Broward Counties have become a haven for criminals who, using stolen identities, file fraudulent Federal tax returns and then cash the refund checks at a local check casher. Effective August 3 through January 30, 2016, the GTO will require check cashers located in those counties to obtain additional identifying information from customers seeking to cash Federal tax refund checks (including refund anticipation loan checks from third parties) that exceed $1,000. Issued in coordination with the IRS and the U.S. Attorney’s Office for the Southern District of Florida, the GTO will require customers to provide the following: (i) a valid government-issued identification; (ii) a digital photograph at the time of the transaction; (iii) a valid phone number; and (iv) a thumbprint. The GTO is intended to put a “roadblock in the path of those who would steal another person’s identity,” making it more difficult for the criminals to evade anti-money laundering controls and “reap the rewards of their actions.”