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.
The FinCEN renewed a Geographic Targeting Order requiring title insurance companies to collect and report beneficial ownership information for certain real estate purchases.
The FinCEN reissued a Geographic Targeting Order requiring title insurance companies to collect and report beneficial ownership information about certain real estate purchases.
The FinCEN extended a Geographic Targeting Order to flag potential money-laundering issues concerning the use of legal entities to purchase residential real estate.
Cadwalader attorneys analyzed the recent Geographic Targeting Order issued by the FinCEN. The Order is part of FinCEN's ongoing efforts to "combat money laundering within the real estate sector."