On May 14 2019, the Financial Crimes Enforcement Network (FinCEN) announced the renewal of its Geographic Targeting Orders (GTOs) focused on all-cash purchases of residential real estate. The GTOs require title insurers and their agents to collect information about the beneficial owners that purchase real estate through corporate entities.
A previous version of the GTOs was issued under a confidentiality order. Because of the stories and feedback on real transactions from title companies, this confidentiality requirement was removed.
Under the GTOs, reports are required for cash transactions by corporate entities in the cities below when the purchase price equals or exceeds $300,000. The extended GTOs run from May 16, 2019 through November 11, 2019.
Covered areas include:
- Texas: Bexar, Tarrant and Dallas counties
- Florida: Miami-Dade, Broward and Palm Beach counties
- New York: Boroughs of Brooklyn, Queens, Bronx, Staten Island and Manhattan
- California: San Diego, Los Angeles, San Francisco, San Mateo and Santa Clara counties
- Hawaii: city and county of Honolulu
- Nevada: Clark County
- Washington: King County
- Massachusetts: Suffolk and Middlesex counties
- Illinois: Cook County
FinCEN reported that previous GTOs provided valuable data on the purchase of residential real estate by persons implicated or allegedly involved in various illicit enterprises, including foreign corruption, organized crime, fraud, narcotics trafficking and other violations. Reissuing the GTOs will further assist in tracking illicit funds and other criminal or illicit activities as well as inform FinCEN’s future regulatory efforts in this sector.
FinCEN praised the continued assistance and cooperation of the title insurance companies and American Land Title Association in protecting the real estate markets from abuse by illicit actors.