FinCEN Renews Geographic Targeting Orders for Residential Real Estate Deals

FinCEN Renews Geographic Targeting Orders for Residential Real Estate Deals


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

On May 15, 2019, 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 in February 2017, August 2017, and November 2018.  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 are identical to the November 2018 GTOs, which covered major metropolitan areas in nine states, added virtual currency to the targeted payment methods, and lowered the monetary threshold for all jurisdictions to $300,000.

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