If you do, you should know that FinCEN has issued another GTO (Geographic Targeting Order). It targets check cashers in Miami-Dade and Broward counties who cash federal tax refund checks and tax refund anticipation loan checks of more than $1000 from August 3, 2015, through January 30, 2016.

Although banks aren't targeted by the order, you may want to share this information with depositors you know will be subject to it. They will have to copy their customer's government-issued photo ID issued in the name of the original check payee (military IDs won't be acceptable, because they can't legally be copied), take a digital photo of the customer showing his/her face, which must be the same as the face on the ID, record the customer's phone number, and make a legible record of the customer's thumbprint on the check.

Wow!

Sort of makes you happy we're on Cape Cod! That, and the summer temps in Miami.

I would think they would have chosen dates ranging from Jan to Aug and not the other way around...wouldn't that be prime tax check cashing season.....

Yes John, these Miami summer temps can be and are brutal - my car thermometer was reading 104 yesterday

They noted that they have detected an increase in post-season activity (attempts at flying under the radar, perhaps?), so they are going after it. There is nothing preventing them from extending the GTO into primo refund season next year, though.

Does this apply to banks as well too that cash tax refund checks for their deposit customers?

No. It applies to check cashers as defined under 31 CFR § 1010.100(ff)(2) that maintain a location (including a branch or agent location) in Miami-Dade County or Broward County.

(2) Check casher—(i) In general. A person that accepts checks (as defined in the Uniform Commercial Code), or monetary instruments (as defined at § 1010.100(dd)(1)(ii), (iii), (iv), and (v)) in return for currency or a combination of currency and other monetary instruments or other instruments, in an amount greater than $1,000 for any person on any day in one or more transactions.

(ii) Facts and circumstances; Limitations. Whether a person is a check casher as described in this section is a matter of facts and circumstances. The term “check casher” shall not include:

(A) A person that sells prepaid access in exchange for a check (as defined in the Uniform Commercial Code), monetary instrument or other instrument;

(B) A person that solely accepts monetary instruments as payment for goods or services other than check cashing services;

(C) A person that engages in check cashing for the verified maker of the check who is a customer otherwise buying goods and services;

(D) A person that redeems its own checks; or

(E) A person that only holds a customer's check as collateral for repayment by the customer of a loan.

Note the definition of check casher is included within the definition of Money Service Business, and the definition of Money Service Business excludes from that definition any bank.

Also, note that I carefully indicated in my OP that banks are not targeted by this order.