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Reporting Requirements Geographic Targeting Order Anti-Money Laundering

IR Global

Understanding FinCEN’s Southwest Border Geographic Targeting Order for Money Service Businesses

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On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Southwest Border Geographic Targeting Order (GTO) aimed at Money Service Businesses (MSBs)[1]. This order is designed to enhance the monitoring and...more

McGuireWoods LLP

FinCEN Narrows Focus on Southwest Border

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In the last few weeks, the Financial Crimes Enforcement Network (FinCEN) has circulated several instructions focusing on money services businesses operating in the southwest United States, answering the current...more

K&L Gates LLP

FinCEN Issues Geographic Targeting Order to Require Certain Money Services Businesses to File CTRs for Smaller Transactions

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On 11 March 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) to require money services businesses (MSBs) located in specified zip codes of California and Texas to file currency...more

Pillsbury Winthrop Shaw Pittman LLP

FinCEN Issues GTO Imposing New Obligations on Southwest Border MSBs

On March 14, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) in the Federal Register that will impose new obligations on many money services...more

Ballard Spahr LLP

FinCEN Issues Southwest Border Geographic Targeting Order Aimed to Combat Mexican-based Drug Cartels

Ballard Spahr LLP on

We have written previously about the new administration’s significant shifts in its approach to criminal enforcement and prosecution of money laundering cases. Specifically, we wrote about shifts at the U.S. Department of...more

Holland & Knight LLP

FinCEN Geographic Targeting Order Imposes Additional Recordkeeping and Reporting Requirements

Holland & Knight LLP on

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on March 11, 2025, issued a Geographic Targeting Order (the Southwest GTO) as part of a "whole-of-government approach" to leverage all...more

DLA Piper

FinCEN’s Geographic Targeting Order Increases Reporting Obligations for Money Services Businesses Located Near the United...

DLA Piper on

On March 11, 2025, the United States Department of the Treasury’s (Treasury) Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) requiring certain money service businesses (MSBs) in...more

Goodwin

FinCEN Adopts Reporting Requirement for Non-Financed Residential Real Estate Transfers

Goodwin on

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued a final rule (the Residential Real Estate Rule) requiring certain persons involved in residential real estate closings and...more

Dorsey & Whitney LLP

FinCEN Proposes AML Compliance Obligations for Non-Financed Real Estate Transactions

Dorsey & Whitney LLP on

Following consideration of comments received from an Advanced Notice of Proposed Rulemaking, on February 16, 2024, FinCEN issued a proposed rule (the “Proposed Rule”) that for the first time would require non-financed...more

Bilzin Sumberg

U.S. Transparency Updates

Bilzin Sumberg on

The United States has started with a bang for 2024 with respect to transparency initiatives. The initiatives affect real estate, financial and business sectors. This alert provides a brief overview of the developments in...more

Morrison & Foerster LLP

FinCEN Proposes Expanding Residential Real Estate Anti-Money Laundering Rules

On February 16, 2024, the Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking, which would require certain real estate professionals to report certain transaction information to FinCEN in...more

Cadwalader, Wickersham & Taft LLP

FinCEN’s Proposed Rulemaking: Enhancing Transparency in Residential Real Estate

While many Americans are struggling to achieve the dream of homeownership, there are criminals that abuse the housing market for financial gain. To avoid the scrutiny of financial institutions that have anti-money laundering...more

Holland & Knight LLP

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

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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

Troutman Pepper Locke

FinCEN's Proposed New Rule to Increase Reporting Requirements in Residential Real Estate

Troutman Pepper Locke on

On February 7, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed a new rule to increase reporting requirements for nonfinanced, entity-purchased residential real estate. FinCEN...more

Bilzin Sumberg

Unanswered Questions on the Corporate Transparency Act

Bilzin Sumberg on

The National Defense Authorization Act for 2021 enacted on January 1, 2021 contains Title LXI, the Corporate Transparency Act (“Act”). It institutes new reporting requirements for legal entities with few employees and limited...more

Ballard Spahr LLP

FinCEN Renews Real Estate GTOs

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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

Foodman CPAs & Advisors

Residential Real Property Purchased with Virtual Currency must be Reported

On November 15, 2018, the Financial Crimes Enforcement Network (FinCEN) announced the issuance of a “Revised” Geographic Targeting Order (GTO) that requires U.S. title insurance companies (Covered Business) to identify the...more

Ballard Spahr LLP

FinCEN Renewal of GTOs for High-End Cash Buyers in Six Markets

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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

The Volkov Law Group

FinCEN Expands Crackdown on Real Estate Buyers

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Building on early successes, the Financial Crimes Enforcement Network (“FinCEN”) announced new rules targeting buyers of high-end real estate properties. Earlier this year, FinCEN adopted rules focusing on high-end...more

Troutman Pepper Locke

FinCEN Issues Geographic Targeting Orders Requiring Identification of High-End Cash Buyers of Real Estate in Manhattan and Miami

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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

Akin Gump Strauss Hauer & Feld LLP

FinCEN Seeks to Curb Trade-Based Money Laundering Through Lowered Reporting Threshold

On April 21, 2015, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a Geographic Targeting Order (“GTO”) lowering reporting thresholds and triggering additional recordkeeping requirements...more

Holland & Knight LLP

FinCEN's New Geographic Targeting Order Focuses on Miami-Based Businesses - Financial Institutions Are Impacted by the GTO

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On April 21, 2015 – after months of speculation by those in the Bank Secrecy Act/anti-money laundering compliance community – the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) in...more

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