FinCEN Renews and Expands Geographic Targeting Orders for Residential Real Estate Deals, Includes Virtual Currencies

FinCEN Renews and Expands Geographic Targeting Orders for Residential Real Estate Deals, Includes Virtual Currencies


By: Michael T. Gershberg, Lawrence Gerschwer, Janice MacAvoy, Justin A. Schenck

On November 15, 2018, the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) announced the six-month renewal of the existing Geographic Targeting Orders (GTOs) relating to money laundering concerns in connection with all-cash purchases of high-end residential real estate properties. The GTOs were originally issued in July 2016 and reissued both in February 2017 and August 2017. They require U.S. title insurance companies to identify and report the ultimate beneficial owners behind legal entities making certain all-cash real estate purchases. The renewed GTOs cover both the original areas in New York, Florida, California, Hawaii, and Texas, and expand their jurisdictions to include parts of Nevada, Washington, Massachusetts, and Illinois. FinCEN also drastically lowered the monetary threshold for all jurisdictions to $300,000, and expanded the scope of the GTOs to include purchases made with virtual currencies, in addition to wire transfers, currency, or checks.

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