On April 21, FinCEN updated its Geographic Targeting Orders (GTOs). The GTOs require U.S. title insurance companies to identify the natural persons behind shell companies that pay “all cash” (i.e., the transaction does not involve external financing) for residential real estate in certain counties within the following major metropolitan areas: Boston; Chicago; Dallas-Fort Worth; Houston; Laredo; Las Vegas; Los Angeles; Miami; New York City; San Antonio; San Diego; San Francisco; Seattle; the District of Columbia, Northern Virginia, and Maryland (DMV) area; as well as the City and County of Baltimore, the County of Fairfield, Connecticut, and the Hawaiian islands of Honolulu, Maui, Hawaii, and Kauai. FinCEN also expanded the geographic coverage of the GTOs to additional counties in both Connecticut and Colorado, after the agency—in conjunction with law enforcement partners—identified the regions as presenting greater risks for illicit finance activity through non-financed purchases of residential real estate. The purchase price required to trigger the reporting requirements in the relevant areas remains set at $300,000, with the exception of the City and County of Baltimore, which is set at $50,000. The renewed GTOs take effect April 25 and end October 21, 2023.

FinCEN FAQs regarding the GTOs are available here.