On January 13, 2016, the Financial Crimes Enforcement Network (FinCEN) issued Geographic Targeting Orders (GTOs) that will require, temporarily, certain title insurance companies to identify the natural persons behind companies used to pay all cash for high-end residential real estate in the Manhattan borough of New York City and in Miami-Dade County, Florida. In issuing these GTOs, FinCEN is exposing its concern that all-cash purchases of this nature may be conducted in an attempt to conceal assets and identities. As part of these GTOs. FinCEN will require certain title insurance companies to report on the beneficial owners of the entities making such purchases of residential real estate. The GTOs will be in effect for 180 days beginning on March 1, 2016 and will expire on August 27, 2016.

The FinCEN press release can be found at: https://www.fincen.gov/news_room/nr/pdf/20160113.pdf