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FinCEN Renews Geographic Targeting Order for 12 Metropolitan Areas

FinCEN renewed a Geographic Targeting Order ("GTO") requiring U.S. title insurance companies to collect and report beneficial ownership information for certain residential real estate purchases. This is the latest iteration of the GTO that was first issued in January 2016 and renews approximately every six months.

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

  • has a purchase price of at least $300,000;

  • is located in a specified area, including the metropolitan areas of Boston, Chicago, Dallas-Fort Worth, Honolulu, Las Vegas, Los Angeles, Miami, New York City, San Antonio, San Diego, San Francisco and Seattle;

  • 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 is effective from November 1, 2021, to April 29, 2022.

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