The Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury is again extending the Global Targeting Orders (GTOs) that impose data collection and reporting requirements on title companies involved in certain high-end real estate transactions.

Set to expire on February 23, 2017, FinCEN discovered that a significant portion of the reported covered transactions in the latest GTOs were linked to possible criminal activity by the individuals revealed to be the beneficial owners of the shell company purchasers. As a result, FinCEN is extending the current GTOs for an additional 180 days, until August 22, 2017, and may consider permanent data collection requirements later this year for more cities.

The GTOs require certain title companies to identify natural persons with a 25 percent or greater ownership interest in a legal entity purchasing residential real property without a bank loan or similar external financing in the following geographic areas meeting specific transaction thresholds:

  • $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 recently updated issue briefpdf.

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 pdfdeveloped in collaboration with the Department of Treasury's Financial Crimes Enforcement Network FinCEN).

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

Notice: The information on this page may not be current. The archive is a collection of content previously published on one or more NAR web properties. Archive pages are not updated and may no longer be accurate. Users must independently verify the accuracy and currency of the information found here. The National Association of REALTORS® disclaims all liability for any loss or injury resulting from the use of the information or data found on this page.
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