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Financial Services Law Insights and Observations

FinCEN renews real estate GTOs

Financial Crimes Of Interest to Non-US Persons FinCEN GTO Anti-Money Laundering

Financial Crimes

On April 17, FinCEN renewed its Geographic Targeting Orders (GTOs) which require title insurance companies to identify the real owners of shell companies involved in cash real estate purchases. This renewal is effective from April 19, through October 15, and applies to specified counties and cities across various states, including California, Florida, New York, and the District of Columbia. The GTOs aim to gather data on potential illicit activities in the housing market and support regulatory initiatives. The minimum property purchase price for reporting remains at $300,000, except in Baltimore, where it is $50,000. FinCEN is also processing feedback from a February proposed rulemaking on anti-money laundering measures for the residential real estate sector.

FinCEN FAQs regarding the GTOs are available here.