FinCEN Expands Scope of “All Cash” GTOs

Continuing its efforts to deter the use of real estate as a vehicle to launder proceeds of criminal activity, the Financial Crimes Enforcement Network (FinCEN) recently announced its plan to extend the reach and time frame of its existing Geographic Targeting Orders (GTOs) targeting “all cash” real estate deals. The new GTOs expand reporting requirements of “all cash” real estate purchases in Manhattan and Miami-Dade County by also including all New York City boroughs (Brooklyn, Queens, the Bronx and Staten Island), Broward and Palm Beach counties (just north of Miami, Fla.), as well as Bexar County, Texas and Los Angeles, San Diego, San Francisco, San Mateo, and Santa Clara counties in California. The new GTOs will begin on August 28, 2016, and continue for another 180 days. During that period, U.S. title insurance companies will be required to identify the natural persons behind shell companies and other entities used to engage in “all cash” purchases of luxury real estate.

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