On April 1, 2025, the Texas Association for Money Service Businesses filed a lawsuit in San Antonio federal court challenging the recent Geographic Targeting Order (GTO) applicable to money services businesses (MSBs) located...more
On March 11, 2025, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) aimed at disrupting drug trafficking and money laundering along the southwestern border. The...more
As we previously blogged, the Financial Crimes Enforcement Center (“FinCEN”) published Anti-Money Laundering Regulations for Residential Real Estate Transfers (“Final Rule”) regarding residential real estate. The Final Rule,...more
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on Feb. 7, 2024, issued a Notice of Proposed Rulemaking (NPRM) proposing a new nationwide reporting obligation to be imposed on settlement...more
FinCEN announced on October 20 that, once again, it is extending the Geographic Targeting Order, or GTO, which requires U.S. title insurance companies to identify the natural persons behind so-called “shell companies” used in...more
On December 6, 2021, the Financial Crimes Enforcement Network (FinCEN) announced an Advance Notice of Proposed Rulemaking (ANPRM) to solicit comments in preparing a proposed rule that would increase transparency in the U.S....more
Law Enforcement Has Been Using GTO Data - First of Two Posts on Evolving Issues Regarding Real Estate and Money Laundering - The U.S. Government Accountability Office (“GAO”) has issued a report on the status and...more
The Financial Crimes Enforcement Network (“FINCEN”) announced on November 15 that it has renewed and revised its Geographic Targeting Orders (“GTOs”) that require U.S. title insurance companies to identify the natural persons...more
A GTO is a Geographic Targeting Order issued by the Financial Crimes Enforcement Network (FinCEN) under the Bank secrecy Act (BSA) for a specific geographic area. ...more
On August 22, 2017, FinCEN (Financial Crimes Enforcement Network) published a new Advisory regarding Geographic Targeting Orders (GTOs) covering residential real estate transactions in certain counties or boroughs of New...more
• The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) continues to expand its Geographic Targeting Orders (GTOs) with respect to beneficial ownership transparency in real estate transactions. ...more
FinCEN has announced the expansion of its Geographical Targeting Orders (GTOs) for high-end cash buyers of real estate. The expansion is two-fold. First, FinCEN has expanded the scope of Form 8300 reportable transactions to...more
The Financial Crimes Enforcement Network (FinCEN) announced the revision of its Geographic Targeting Orders (GTO) Tuesday. The GTO requires title insurers to report beneficial ownership information on legal entities,...more
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on Jan. 13, 2016, issued a Geographic Targeting Order (GTO or the Order) requiring title insurance companies, subsidiaries and agents (each a...more
Reporting Leases on the Balance Sheet - The International Accounting Standards Board (IASB) announced on Jan. 13, 2016, a new – and materially different – manner of accounting for leases. The new standard, IFRS 16...more
The U.S. government’s aggressive push to combat international money laundering is entering a new phase by focusing on real estate investments. On January 13, 2016, the Financial Crimes Enforcement Network (FinCEN), the U.S....more
On January 13, 2016, the U.S. Treasury’s financial intelligence unit, known as the Financial Crimes Enforcement Network (FinCEN), announced the issuance of geographic targeting orders (GTOs) to certain unnamed real estate...more
On January 13, 2016, the Financial Crimes Enforcement Network (“FinCEN”) announced that it had issued a Geographic Targeting Order (“GTO”) which will temporarily require certain title insurance companies to report the...more
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...more
Following the September 10, 2014 historic seizure of $100 million in cash from the execution of approximately 70 business search warrants in the Los Angeles Fashion District, the Financial Crimes Enforcement Network (FinCEN)...more
In the latest development in a probe by U.S. Immigration and Customs Enforcement’s (ICE) Homeland Security Investigations (HSI) targeting alleged money laundering activities in Los Angeles’ garment trade, the Financial Crimes...more