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FinCEN Renews and Expands Geographic Targeting Orders for Residential Real Estate Deals

Client memorandum | May 2, 2022

On April 29, 2022, 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. It also expanded the GTOs to new real estate markets in the District of Columbia, Maryland, and Virginia area, Connecticut, Baltimore, and Hawaii. The GTOs were originally issued in July 2016 and have been reissued several times, most recently in November 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.

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