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FinCEN GTOs reissued

FinCEN has announced the renewal of its Geographic Targeting Orders (GTOs) that require U.S. title insurance companies to identify the natural persons behind shell companies used in all-cash purchases of residential real estate. The renewed GTOs will be identical to the May 2019 GTOs with one modification: the new GTOs will not require reporting for purchases made by legal entities that are U.S. publicly-traded companies. Real estate purchases by such entities are identifiable through other business filings.

The terms of this Order are effective beginning November 12, 2019 and ending on May 9, 2020. It applies to purchases made without a bank loan or other similar form of external financing and paid for, at least in part, using currency or a cashier's, certified, traveler's, personal or business check, a money order in any form, a funds transfer, or virtual currency. Covered transactions are those involving residential real property in the:

  • Texas counties of Bexar, Tarrant, or Dallas;
  • Florida counties of Miami-Dade, Broward, or Palm Beach;
  • Boroughs of Brooklyn, Queens, Bronx, Staten Island, or Manhattan in New York City, New York;
  • California counties of San Diego, Los Angeles, San Francisco, San Mateo, or Santa Clara;
  • City and County of Honolulu in Hawaii;
  • Nevada county of Clark;
  • Washington county of King;
  • Massachusetts counties of Suffolk, or Middlesex; or
  • Illinois county of Cook
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