On April 19, 2024, the Financial Crimes Enforcement Network (FinCEN) renewed Real Estate Geographic Targeting Orders (GTOs), mandating U.S. Title Insurance companies to identify the natural persons behind so-called “shell companies” involved in residential real estate purchases without mortgages.
These GTOs continue to yield valuable data on residential real estate purchases potentially linked to various illicit enterprises.
The key provisions include:
- • The purchase amount threshold remains at USD 300,000 for each covered metropolitan area, except in Baltimore city and county, where it stands at USD 50,000.
- • Businesses must report Covered Transactions to FinCEN by filing a FinCEN Currency Transaction Report within 30 days of closing.
- • The GTO terms are effective from April 19, 2024, until October 15, 2024.
- • Covered Businesses are required to maintain compliance records for five years, ensuring accessibility and availability to FinCEN or other law enforcement agencies upon request.
The designated GTO areas encompass:
Texas: Bexar, Tarrant, Dallas, Montgomery, Harris, or Webb, Travis Counties
Florida: Miami-Dade, Broward, Palm Beach, Hillsborough, Pasco, Pinellas, Manatee, Sarasota, Charlotte, Lee, and Collier Counties
Maryland: Montgomery, Anne Arundel, Prince George’s, Howard Counties, Baltimore City, and County.
New York: Boroughs—Brooklyn, Queens, Bronx, Staten Island, or Manhattan
California: San Diego, Los Angeles, San Francisco, San Mateo, or Santa Clara Counties
Colorado: Adams, Arapahoe, Clear Creek, Denver, Douglas, Eagle, Elbert, El Paso, Fremont, Jefferson, Mesa, Pitkin, Pueblo, or Summit Counties
Connecticut: Fairfield or Litchfield County
District of Columbia
Hawaii: City and County of Honolulu, Maui, and Kauai
Nevada: Clark County
Virginia: Arlington or Fairfax Counties; or the cities of Alexandria, Falls Church, or Fairfax
Washington: King County
Massachusetts: Suffolk or Middlesex, Bristol, Essex, Norfolk, and Plymouth Counties
Illinois: Cook County
