FinCEN Renews and Expands Geographic Targeting Orders
FinCEN renewed and expanded its Geographic Targeting Orders ("GTOs") requiring U.S. title insurance companies to collect and report beneficial ownership information for certain residential real estate purchases.
The renewal Orders expand pre-existing authority (see previous coverage) to include "additional regions that present greater risks for illicit finance activity through all-cash purchases of residential real estate" including (i) parts of the District of Columbia, Northern Virginia and Maryland (DMV) metropolitan area, (ii) Maui, Hawaii and Kauai counties in Hawaii, (iii) Fairfield County, Connecticut and (iv) the City and County of Baltimore.
The purchase amount threshold remains unchanged at $300,000, except for in the City and County of Baltimore, where the purchase threshold is $50,000.
The GTOs are effective from April 30, 2022 to October 26, 2022.