On October 9, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced that it was renewing residential real estate Geographic Targeting Orders (“GTOs”), effective October 10, 2025. The GTOs require U.S. title insurance companies to collect and report the names of natural persons behind shell companies used in non-financed purchases of residential real estate, within 30 days of closing a covered transaction. The GTOs apply to residential real estate with a purchase price of at least $300,000 that is located in certain counties and U.S. metropolitan areas in California, Colorado, Connecticut, Florida, Hawaii, Illinois, Maryland, Massachusetts, Nevada, New York Texas, Washington, Virginia, and the District of Colombia. The GTOs also apply to residential real estate with a purchase price threshold of $50,000 in the City and County of Baltimore.
On September 30, 2025, FinCEN also announced that it was postponing the enforcement of reporting requirements pursuant to the Anti-Money Laundering Regulations for Residential Real Estate Transfers Rule (“RRE Rule”), until March 1, 2026. FinCEN indicated that the renewed residential real estate GTOs will expire on February 28, 2026.
FinCEN News Release | Geographic Targeting Order | GTO – Frequently Asked Questions