FinCEN renews Geographical Targeting Order for cash real estate purchases

On October 29, 2021, the Financial Crimes Enforcement Network announced the renewal its Geographical Targeting Order applicable to title insurance companies in the United States.  The GTO, which took effect on November 1, 2021, and expires on April 29, 2022, is issued pursuant to FinCEN’s authority under the Bank Secrecy Act, and imposes additional recordkeeping and reporting requirements on the relevant financial institutions.  Specifically, it requires title insurance companies to identify holders of shell companies involved in cash real estate transactions valued at $300,00 or more in the Boston, Chicago, Dallas-Fort Worth, Honolulu, Las Vegas, Los Angeles, Miami, New York, San Antonio, San Diego, San Francisco and Seattle metropolitan areas, including some of the surrounding counties.  FinCEN has issued eight Frequently Asked Questions to guide institutions in satisfying the requirements of the GTO.

FinCEN press release | GTO | FAQs