FinCEN Renews Real Estate Geographic Targeting Orders

The Financial Crimes Enforcement Network ("FinCEN") renewed Geographic Targeting Orders ("GTOs") that temporarily require U.S. title insurance companies to identify natural persons who use shell companies and pay cash for high-end residential real estate in six major metropolitan areas. FinCEN determined previously that approximately 30 percent of the transactions covered by the GTOs involved a "beneficial owner or purchaser representative that [was] also the subject of a previous suspicious activity report," which corroborated FinCEN's "concerns about the use of shell companies to buy luxury real estate in 'all-cash' transactions."

The GTOs apply to the following major U.S. geographic areas: all New York City boroughs; Miami-Dade, Broward and Palm Beach Counties; Los Angeles County; San Francisco, San Mateo and Santa Clara Counties; and Bexar County, which includes San Antonio.

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