FinCEN Targets “All Cash” Real Estate Deals in Manhattan and Miami

On January 13, 2016, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of Treasury (Treasury), as part of its continued efforts to combat money laundering, issued its first Geographic Targeting Orders (GTOs) of 2016. The GTOs are directed exclusively at U.S. title insurance companies and their subsidiaries and agents, requiring them, for a temporary period, to identify the individuals behind any entity that is used to purchase high-end residential real estate in Manhattan (New York) and Miami-Dade County (Florida) on an “all cash” basis. This alert addresses the immediate impact of these GTOs on the title insurance companies, and previews what the GTOs may mean for the real estate industry more broadly.

Please see full Alert below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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