May 15, 2019

FinCEN renews reporting requirements for cash purchases of some residential real estate

The Financial Crimes Enforcement Network of the US Department of the Treasury announced that it has renewed Geographic Targeting Orders (GTOs) for cash purchases of residential real estate over $300,000, pursuant to the authority granted to FinCEN under 31 USC § 5326(a); 31 CFR § 1010.370 and Treasury Order 180-01, in order to implement and prevent evasion of the Bank Secrecy Act.  GTOs require US title insurance companies to identify the natural persons who stand behind all-cash purchases that meet the threshold amount.  The GTOs renewed by FinCEN target major metropolitan real estate markets including Boston, Chicago, Dallas-Fort Worth, Honolulu, Las Vegas, Los Angeles, Miami, New York, San Antonio, San Diego, San Francisco and Seattle, and require the filing of a currency transaction report within 30 days of a covered transaction.

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