Washington Report

Advocacy Updates from Washington D.C.

FinCEN Renews Its Geographic Targeting Order (GTO)

The Financial Crimes Enforcement Network (FinCEN) renewed its Geographic Targeting Orders (GTOs) requiring title insurance companies to identify the natural persons behind shell companies used in all-cash purchases of residential real estate in 12 metropolitan cities. The GTOs since inception have focused on non-financed, residential real estate transactions in certain markets. The current GTO is effective beginning November 1, 2021 until April 29, 2022. The GTO imposes reporting requirements on title companies in 12 key metropolitan cities:

  • Boston
  • Chicago
  • Dallas-Fortworth
  • Honolulu
  • Las Vegas
  • Los Angeles
  • Miami
  • New York City
  • San Antonio
  • San Diego
  • San Francisco
  • Seattle

The current order also covers transactions involving non-financed, residential real estate of $300k or more in the covered GTO jurisdictions. FinCEN asserts that “renewing the GTOs will further assist in tracking illicit funds and other criminal or illicit activity.”

NAR will continue to provide anti-money laundering and GTO updates. For more in-depth information about the new GTO, check out NAR's Issue Brief: FinCEN's Renewed Geographic Targeting Order.

For additional information, please visit NAR's Money Laundering and Terrorism Financing topic page at nar.realtor/money-laundering-and-terrorism-financing.