Washington Report

Advocacy Updates from Washington D.C.

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

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 brief.

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 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.

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