The Financial Crimes Enforcement Network (FinCEN) has renewed the Geographic Targeting Orders (GTOs) imposing data collection and reporting requirements on title companies involved in certain high-end real estate transactions. The GTOs do not impose any new obligations on real estate professionals, except to the extent that a transaction is covered by a GTO and the title company needs to consult with the real estate professional to obtain information necessary to maintain compliance with the order. FinCEN has extended the GTOs until September 2018 covering the following geographic areas and transactions:
- $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
- $3m and above – City and County of Honolulu, Hawaii.
NAR also recently participated on an industry panel in a “Money Laundering in Real Estate” conference hosted by George Mason University’s Terrorism, Transnational Crime and Corruption Center along with representatives from the American Land Title Association and the American Escrow Association. The conference provided valuable insight into the vulnerabilities of the real estate industry as a target for money laundering schemes. While many argued for the need to increase regulations on the industry to crack down on such schemes, NAR explained that such regulations would prove burdensome and unnecessary given the existing anti-money laundering regulations that already apply to U.S. financial institutions.
For background on this issue, visit the NAR homepage on money laundering.
For real estate professionals' responsibilities under the law, check out NAR’s voluntary guidelines developed with the help of FinCEN.
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 help recognizing suspicious money laundering activities, see this video created by NAR in partnership with U.S. Treasury Department.