FinCEN Reissues Geographic Targeting Order for 12 Metropolitan Areas

FinCEN reissued a Geographic Targeting Order ("GTO") requiring title insurance companies to collect and report beneficial ownership information for certain residential real estate purchases.

The renewed GTO applies when a legal entity purchases residential real estate that:

  • is in one of the specified areas (e.g., Boston, Chicago, Dallas-Fort Worth, Honolulu, Las Vegas, Los Angeles, Miami, New York City, San Antonio, San Diego, San Francisco and 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, a cashier's check, a certified check, a traveler's check, a personal check, a business check, a money order, a funds transfer or virtual currency.

The GTO covers the period from May 5, 2021 to October 31, 2021.

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