FCC RegUpdate

On October 20, 2023, the Financial Crimes Enforcement Network (FinCEN) reissued and expanded Real Estate Geographic Targeting Orders (GTOs). These GTOs mandate that U.S. title insurance companies identify the natural persons behind ‘shell companies’ used in residential real estate purchases not involving a mortgage.

To know more, click here https://www.fcctimes.com/2023/10/20/fincen-extends-and-expands-geographic-targeting-orders-to-combat-illicit-real-estate-activities/

These GTOs continue to provide invaluable data on residential real estate purchases by individuals possibly involved in various illicit activities. The key focus areas of this expansion are as follows:

  • The GTOs have once again been expanded, now covering the following counties: Bristol, Essex, Norfolk, and Plymouth in Massachusetts; Hillsborough, Pasco, Pinellas, Manatee, Sarasota, Charlotte, Lee, and Collier in Florida; and Travis County in Texas.
  • The purchase amount threshold remains at USD 300,000 for each covered metropolitan area, with the exception of the city and county of Baltimore, where the threshold is USD 50,000.
  • Businesses are required to report Covered Transactions to FinCEN by filing a FinCEN Currency Transaction Report within 30 days of the transaction’s closing.
  • The GTOs are effective from October 22, 2023, to April 18, 2024.
  • Covered businesses must maintain compliance records for five years, ensuring they are accessible and available to FinCEN or other law enforcement agencies upon request.