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FinCEN Renews Geographic Targeting Order for 12 Metropolitan Areas

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.

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