News & Analysis as of

GTO Suspicious Activity Reports (SARs)

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

Ballard Spahr LLP

FinCEN Renews and Expands GTO

Ballard Spahr LLP on

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

Ballard Spahr LLP

GAO Publishes Report on Effectiveness of Real Estate GTOs Issued by FinCEN

Ballard Spahr LLP on

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

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

Ballard Spahr LLP

FinCEN Continues Its Focus on Real Estate Transactions through Advisory and GTOs

Ballard Spahr LLP on

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

Burr & Forman

Aloha Cash Buyers: FinCEN Issues Advisory to Financial Institutions; Expands Geographic Tracking Order to Include Honolulu, Wire...

Burr & Forman on

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

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