On October 15, FinCEN renewed its Geographic Targeting Orders (GTOs) requiring U.S. title insurance companies to report the identities of individuals behind shell companies used in non-financed residential real estate purchases. The renewed GTOs, effective from October 16, 2024, to April 14, 2025, cover specific counties and metropolitan areas in California, Colorado, Connecticut, Florida, Hawaii, Illinois, Maryland, Massachusetts, Nevada, New York, Texas, Virginia, Washington and the District of Columbia, with a purchase price threshold of $300,000. There is one exception for the City and County of Baltimore, where the purchase price threshold is $50,000. The order mandated that title insurance companies report transactions involving residential real estate purchases by legal entities without bank loans, using various forms of payment, including currency and checks. The companies must file a FinCEN Currency Transaction Report within 30 days of closing such transactions, detailing the identities of the individuals and entities involved, the purchase price, and the method of payment.
