The FinCEN renewed a Geographic Targeting Order ("GTO") requiring title insurance companies to collect and report beneficial ownership information for certain real estate purchases.
The reissued 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 or a cashier's check, certified check, traveler's check, personal check, business check, money order, funds transfer or virtual currency.
The GTO will be effective from May 16, 2019 to November 11, 2019.
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."