On April 29, 2021, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced the 6-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 have been reissued several times, most recently in November 2020
. 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 2020 GTOs, which covered major metropolitan areas in nine states, continued the lower monetary threshold of $300,000 for all jurisdictions, and included virtual currency as a targeted payment method.