News & Analysis as of

GTO Cash Transactions

Holland & Knight LLP

FinCEN Proposal for Nonfinanced Purchases of Residential Real Estate and Gratuitous Transfers

Holland & Knight LLP on

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

Foodman CPAs & Advisors

New GTO covers Wire Transfers

Foodman CPAs & Advisors on

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

Holland & Knight LLP

FinCEN Expands GTOs and Closes Wire Transfer Loophole

Holland & Knight LLP on

• 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

Manatt, Phelps & Phillips, LLP

Can New Beneficial Owner Identification Requirement for Cash-Only Real Estate Deals in Miami and New York City Be Avoided if...

Why it matters - After years of concern about money laundering through shell corporations, repeated legislative and regulatory efforts to gain more information on beneficial owners of entities involved in various types...more

Pillsbury Winthrop Shaw Pittman LLP

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...more

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