Washington Report

Advocacy Updates from Washington D.C.

FinCEN Expands Anti-Money Laundering Efforts for High-End Real Estate Transactions

The Financial Crimes Enforcement Network (FinCEN) – the U.S. Department of Treasury’s lead agency in the fight against money laundering – issued a notice expanding upon two previously released Global Targeting Orders (GTOs) imposing new data collection and reporting requirements on title companies involved in certain high-end real estate transactions. In March of this year, FinCEN issued two GTOs requiring specific title companies to identify natural persons with a 25 percent or greater ownership interest in a legal entity making an all cash real estate purchase in excess of $3 million dollars in the Borough of Manhattan in New York or in excess of $1 million in Miami-Dade County, Florida. Set to expire next month, FinCEN discovered that a significant portion of the reported covered transactions were linked to possible criminal activity by the individuals revealed to be the beneficial owners of the shell company purchasers.

As a result, FinCEN has expanded the covered geographic areas where title companies must comply with the GTO’s data collection and reporting requirements. Effective August 28, 2016, through February 23, 2017, the new GTO covers the following geographic areas and transactions:

  • $500k and above – Bexar County, Texas
  • $1m and above – Miami-Dade, Broward, and Palm Beach Counties, Florida
  • $1.5m and above – New York City Boroughs of Brooklyn, Queens, Bronx, and Staten Island
  • $2m and above – San Diego, Los Angeles, San Francisco, San Mateo, and Santa Clara Counties, California
  • $3m and above – New York City Borough of Manhattan

For more information on FinCEN's latest GTO, refer to the issue summary

To learn more about anti-money laundering and FinCEN’s efforts, see NAR’s Window to the Law: New Effort to Combat Money Laundering.

For background on real estate professionals’ responsibilities under the law, check out NAR’s voluntary guidelines developed in collaboration with FinCEN.

For help recognizing suspicious money laundering activities, see this video created by NAR in partnership with U.S. Treasury Department.

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