The Financial Crimes Enforcement Network (FinCEN) recently renewed its Geographic Targeting Order (GTOs) on November 6, 2020 and the order ends on May 4, 2021. This order imposes data collection and reporting requirements on companies involved in certain residential real estate transactions.
This GTOs were initially started issued by FinCEN in 2016, and a new order has been issued every six months. The orders impose data collection and reporting requirements on title companies for all cash purchases of residential real estate in certain jurisdictions throughout the country. The purpose of the GTOs is to assist law enforcement and federal regulators with tracking bad actors engaged in financial illicit crimes involving real estate.
The latest GTO covers the following geographic areas listed below, which remain unchanged from the last order for residential, non-financed transactions of $300k or more:
- California: San Diego, Los Angeles, San Francisco, San Mateo, or Santa Clara Counties
- Florida: Miami-Dade, Broward, or Palm Beach Counties
- Hawaii: City and County of Honolulu
- Illinois: Cook County (Chicago)
- Massachusetts: Suffolk or Middlesex Counties (Boston)
- Nevada: Clark County (Las Vegas)
- New York: the Boroughs of Brooklyn, Queens, Bronx, Staten Island, or Manhattan
- Texas: Bexar County (San Antonio), Tarrant County (Fort Worth), or Dallas County
- Washington: King County (Seattle)
NAR continues to monitor changes to the GTOs, and continues to advocate for pragmatic, risk-based anti-money laundering reforms.