Geographic Targeting Orders reissued by FinCEN

The Financial Crimes Enforcement Network has announced the renewal of Geographic Targeting Orders for twelve metropolitan areas in the US.  The GTOs require US title insurance companies to identify the natural persons behind residential cash real estate purchases over $300,000 in counties surrounding Boston, Chicago, Dallas-Fort Worth, Honolulu, Las Vegas, Los Angeles, Miami, New York City, San Antonio, San Diego, San Francisco, and Seattle.  FinCEN expects relevant business to implement procedures reasonably designed to ensure compliance with the terms of the GTOs.  According to FinCEN, GTOs help track illicit funds, and provide valuable data about the purchase of real by persons who may be involved in criminal activities.  The GTOs will remain in effect for six months beginning May 10, 2020, and are identical to the expiring GTOs they replace.

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