Friday, May 7, 2021
The Financial Crimes Enforcement Network (FinCEN) today 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 GTOs are identical to the November 2020 GTOs. The purchase amount threshold remains $300,000 for each covered metropolitan area.
The terms of this Order are effective beginning May 5, 2021 and ending October 31, 2021. GTOs continue to provide valuable data on the purchase of residential real estate by persons possibly involved in various illicit enterprises. Renewing 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.
FinCEN appreciates the continued assistance and cooperation of the title insurance companies and the American Land Title Association in protecting the real estate markets from abuse by illicit actors.
Any questions about the Orders should be directed to FinCEN’s Regulatory Support Section at FRC@FinCEN.gov.
A copy of the GTO is available here (
Frequently asked questions regarding these GTOs are available here.