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Exception Tracking Spreadsheet (TicklerTrax™)
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FinCEN reactivates real estate GTOs in 12 markets

On Wednesday, FinCEN announced it is reissuing its real estate Geographic Targeting Orders (GTOs) for 12 metro areas. 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 purchase amount threshold remains $300,000 for each covered metropolitan area. The orders provide FinCEN valuable data on the purchase of residential real estate by persons possibly involved in various illicit enterprises. Reissuing the GTOs will further assist in tracking illicit funds and other criminal or illicit activity, as well as inform FinCEN’s future regulatory efforts in this sector.

The GTOs cover certain counties within the following major U.S. metropolitan areas: Boston; Chicago; Dallas-Fort Worth; Honolulu; Las Vegas; Los Angeles; Miami; New York City; San Antonio; San Diego; San Francisco; and Seattle. They are effective beginning May 16, 2019, and ending November 11, 2019, but can be renewed.

FinCEN also posted an FAQ about the GTOs, which don't directly affect banks..

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