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Financial Services Law Insights and Observations

FinCEN renews GTOs covering 12 metropolitan areas; continued focus on AML risk in related shell companies

Financial Crimes Agency Rule-Making & Guidance FinCEN GTO Anti-Money Laundering Of Interest to Non-US Persons

Financial Crimes

On May 15, the Financial Crimes Enforcement Network (FinCEN) announced the renewal of its Geographic Targeting Order (GTO), which requires U.S. title insurance companies to identify the natural persons behind shell companies that pay “all cash” (i.e., the transaction does not involve external financing) for high-end residential real estate in 12 major metropolitan areas. The purchase amount threshold for the beneficial ownership reporting requirement remains set at $300,000 for residential real estate purchased in the 12 covered areas.

The renewed GTO takes effect May 16, and covers certain counties within the following areas: Boston; Chicago; Dallas-Fort Worth; Honolulu; Las Vegas; Los Angeles; Miami; New York City; San Antonio; San Diego; San Francisco; and Seattle.

FinCEN FAQs regarding GTOs are available here.

Previous InfoBytes coverage on FinCEN GTOs available here.

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