FinCEN Reissues Geographic Targeting Order for 2019-2020

We previously wrote on this issue in 2017 –

Last November 2019, FinCEN renewed a Geographic Targeting Order (“GTO”) requiring title insurance companies to collect and report beneficial ownership information for certain real estate purchases. The Order is effective from November 12, 2019 to May 9, 2020.

According to FinCEN, the reissued GTO is similar to the May 2019 GTO but with one change: title insurance companies no longer will be required to report purchases made by entities that are U.S. publicly traded companies. As previously covered, the reissued GTO applies when a legal entity purchases residential real estate that:

  • is in one of the specified areas (i.e., Boston, Chicago, Dallas-Fort Worth, Honolulu, Las Vegas, Los Angeles, Miami, New York City, San Antonio, San Diego, San Francisco or Seattle);
  • sells for at least $300,000;
  • does not involve a bank loan or similar external financing; and
  • is purchased, at least in part, with currency or a cashier’s check, certified check, traveler’s check, personal check, business check, money order, funds transfer or virtual currency.


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