News & Analysis as of

Title Insurance Real Estate Market FinCEN

Orrick, Herrington & Sutcliffe LLP

FinCEN renews and expands real estate GTOs

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

Morrison & Foerster LLP

FinCEN Looks to Regulate the Real Estate Market

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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

Ballard Spahr LLP

FinCEN Renews Real Estate GTOs

Ballard Spahr LLP on

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

Ballard Spahr LLP

Treasury Report Targets Money Laundering Risks in Real Estate and Gatekeeper Professions

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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

Ballard Spahr LLP

FinCEN Renews GTOs

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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

Ballard Spahr LLP

FinCEN Again Extends Real Estate GTOs

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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

Ballard Spahr LLP

FinCEN Renews Real Estate GTOs: Expanded Geographic Coverage and Reduced Monetary Thresholds

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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

Foodman CPAs & Advisors

Did you know that GTO’s have a $300,000 Threshold?

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

Fox Rothschild LLP

FinCEN Quietly Extends Real Estate Geographic Targeting Orders For Another Six Months

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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

Pillsbury - Gravel2Gavel Construction & Real...

FinCEN Expands Its AML Target Real Estate Deals and Information Collection

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

Holland & Knight LLP

West Coast Real Estate Update: March 2017

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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

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

Pillsbury Winthrop Shaw Pittman LLP

FinCEN Expands Scope of “All Cash” GTOs

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

Ballard Spahr LLP

FinCEN Expands Targeting of High-End Cash Real Estate Transactions

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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

Cadwalader, Wickersham & Taft LLP

FinCEN Tightens the Screws on Money Launderers with Additional Scrutiny of High-Value Residential Real Estate Transactions

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

Locke Lord LLP

U.S. Treasury Department to Scrutinize Certain All Cash Real Estate Transactions in New York City and Miami-Dade County

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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

Cadwalader, Wickersham & Taft LLP

FinCEN Targets High-Value Real Estate Transactions in New York and Miami

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

Blank Rome LLP

FinCEN Cracks Down on Real Estate Secrecy in Manhattan and Miami

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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

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