On April 21, FinCEN updated its Geographic Targeting Orders (GTOs). The GTOs require U.S. title insurance companies to identify the natural persons behind shell companies that pay “all cash” (i.e., the transaction does not...more
As expected, on May 8, 2020, the Financial Crimes Enforcement Network (“FinCEN”) reissued its Geographic Targeting Orders (“GTOs”) requiring U.S. title insurance companies to identify the natural persons behind legal entities...more
In its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”), the U.S. Department of Treasury (“Treasury”) has laid out its AML and money laundering enforcement priorities. Last week, we...more
On November 8, 2019, the Financial Crimes Enforcement Network (“FinCEN”) reissued its Geographic Targeting Orders (“GTOs”) requiring U.S. title insurance companies to identify the natural persons behind legal entities used in...more
The Financial Crimes Enforcement Network (“FinCEN”) has, once again, extended its Geographic Targeting Order (“GTO”) requiring U.S. title insurance companies to identify the natural persons behind legal entities used in...more
The Standing Committee on Finance (Committee) recently released its report, Confronting Money Laundering and Terrorist Financing: Moving Canada Forward (Report), where it makes 32 recommendations on proposed modifications and...more
We previously reported that the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) had quietly extended its Geographic Targeting Orders directed at the luxury residential real estate market for another six...more
Breaking from its recent practice of making public announcements about Geographic Targeting Orders, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) last month quietly extended its real estate GTOs for...more
This article is Part II of a series in which we address the U.S. government’s attempts to combat money laundering in real estate transactions....more
This article is Part I of a series in which we address the U.S. government’s attempts to combat money laundering in real estate transactions. This week the Treasury Department’s Financial Crimes Enforcement Network...more
The Financial Crimes Enforcement Network (FinCEN) announced on August 22, 2017, that it is expanding its earlier Geographic Targeting Orders (GTO) that require U.S. title insurance companies to identify the natural persons...more
Yesterday the Financial Crimes Enforcement Network (FinCEN) announced the issuance of revised Geographic Targeting Orders (GTOs) that require U.S. title insurance companies to identify the natural persons behind shell...more
Gov. Brown Opposes Measure S - In a statement published less than two weeks before Los Angeles' Consolidated Municipal and Special Elections to be held on March 7, 2017, California Gov. Jerry Brown came out in opposition...more
FinCEN announced today that it is renewing the existing Geographical Targeting Orders (GTOs) issued in July 2016 that require all title insurance companies to identify and report on the natural persons behind shell companies...more
2016 was a busy year for developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues. In part one of our year-in-review, we discuss six key...more
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...more
FinCEN has announced a major expansion and extension of its geographic targeting orders (GTOs) aimed at high-end cash buyers of real estate. This action reflects FinCEN’s continued efforts to prevent money laundering through...more
Choice real estate markets such as New York, Miami, Los Angeles, San Francisco, San Diego, and San Antonio may offer enticing amenities like buzzing nightlife or sunny beaches, but thanks to the Financial Crimes Enforcement...more
Today, the Financial Crimes Enforcement Network (FinCEN) announced, effective August 28, 2016golden and continuing for 180 days, it is expanding its earlier Geographic Targeting Orders (GTO) requiring information about the...more
The Financial Crimes Enforcement Network's (FinCEN) continuing efforts to address the "real estate industry's vulnerability to money laundering” were outlined by FinCEN Director Jennifer Shasky Calvery in an April 12, 2016,...more
In yet another sign of its aggressive campaign to fight money laundering, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) has trained its sights on the high-end real estate market in New York and...more
On January 13, 2016, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued two temporary Geographic Targeting Orders (the Orders) that will require title insurance companies to identify...more
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...more
In yet another indication of its aggressive efforts to fight money laundering, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) today issued another Geographic Targeting Order (GTO), this time targeting...more