On October 26th, 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, October 27, 2022 until April 24, 2023, and includes additional jurisdictions in Texas, including Webb, Montgomery, and Harris counties. These are counties bordering the cities of Houston and Laredo, Texas. 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.