The Financial Crimes Enforcement Network has re-issued Geographic Targeting Orders for counties in the same twelve metropolitan areas that have been the focus of earlier GTOs: New York, Los Angeles, San Francisco, Chicago, Dallas-Fort Worth, Boston, Las Vegas, Honolulu, San Diego and Seattle. The renewed GTOs are triggered when residential real estate in the targeted areas that is valued over $300,000 is purchased by cash. They require US title insurance companies to identify the natural persons behind such cash transactions by filing Currency Transaction Reports with FinCEN within 30 days of the real estate closing.
The purpose of these GTOs, which are effective from November 6, 2020 through May 4, 2021, is to assist law enforcement in tracking illicit funds, and to carry out the purposes of the Bank Secrecy Act. Businesses that fail to comply with the requirements of the GTOs, as well as their officers, directors and agents, may be liable for civil or criminal penalties.