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FinCEN Again Renews Geographic Targeting Orders for Residential Real Estate Deals

Client memorandum | November 2, 2021

On October 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 May 2021.  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 May 2021 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.

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