FinCEN Expands Geographic Targeting Orders

The Financial Crimes Enforcement Network (FinCEN) recently announced the renewal and expansion of its Geographic Targeting Orders (GTOs) that require U.S. title insurance companies to identify the natural person behind shell companies used in the purchase of residential real estate when such purchase is made in part using currency, a cashier’s check, a certified check, a traveler’s check, a personal check, a business check, a money order in any form, a funds transfer, or virtual currency, when bank or other external financing is not used.

The GTOs are expanded to cover parts of the District of Columbia, Maryland, and Northern Virginia, certain Hawaiian Islands, and Fairfield County, Connecticut, in addition to the metropolitan areas that were already covered. The threshold amount for residential real estate purchases remains at $300,000 for most locations, but note that the threshold is $50,000 for the City and County of Baltimore.

The GTOs are effective beginning April 30, 2022, and ending on October 26, 2022.