Washington Report

Advocacy Updates from Washington D.C.

FinCEN Renews and Expands its Geographic Targeting Order (GTO)

On April 29th, the Financial Crimes Enforcement Network (FinCEN) renewed its Geographic Targeting Order (GTOs) and expanded the jurisdictions that are subject to the GTOs.

The GTOs require U.S. title insurance companies to identify the natural persons behind shell companies used in all-cash purchases of residential real estate.

The current GTO is effective beginning, April 30, 2022 until October 26, 2022, and includes additional jurisdictions including parts of the District of Columbia, Northern Virginia, and Maryland, the Hawaiian islands of Maui, and Kauai, and the County of Fairfield, Connecticut. The reporting threshold amount is $300,000 for each covered jurisdiction, except Baltimore City and County where the reporting threshold amount is $50,000.

FinCEN also issued updated Frequently Asked Questions (FAQs) regarding the GTOs.

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