News & Analysis as of

Title Insurance Real Estate Investments Geographic Targeting Order

Morrison & Foerster LLP

FinCEN Proposes Expanding Residential Real Estate Anti-Money Laundering Rules

On February 16, 2024, the Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking, which would require certain real estate professionals to report certain transaction information to FinCEN in...more

Orrick, Herrington & Sutcliffe LLP

FinCEN renews and expands real estate GTOs

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...more

Ballard Spahr LLP

FinCEN Renews Real Estate GTOs

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As expected, on May 8, 2020, the Financial Crimes Enforcement Network (“FinCEN”) reissued its Geographic Targeting Orders (“GTOs”) requiring U.S. title insurance companies to identify the natural persons behind legal entities...more

Ballard Spahr LLP

Treasury Report Targets Money Laundering Risks in Real Estate and Gatekeeper Professions

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In its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”), the U.S. Department of Treasury (“Treasury”) has laid out its AML and money laundering enforcement priorities. Last week, we...more

Ballard Spahr LLP

FinCEN Again Extends Real Estate GTOs

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The Financial Crimes Enforcement Network (“FinCEN”) has, once again, extended its Geographic Targeting Order (“GTO”) requiring U.S. title insurance companies to identify the natural persons behind legal entities used in...more

Foodman CPAs & Advisors

Residential Real Property Purchased with Virtual Currency must be Reported

On November 15, 2018, the Financial Crimes Enforcement Network (FinCEN) announced the issuance of a “Revised” Geographic Targeting Order (GTO) that requires U.S. title insurance companies (Covered Business) to identify the...more

Holland & Knight LLP

West Coast Real Estate Update: March 2017

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Gov. Brown Opposes Measure S - In a statement published less than two weeks before Los Angeles' Consolidated Municipal and Special Elections to be held on March 7, 2017, California Gov. Jerry Brown came out in opposition...more

Ballard Spahr LLP

FinCEN Renewal of GTOs for High-End Cash Buyers in Six Markets

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FinCEN announced today that it is renewing the existing Geographical Targeting Orders (GTOs) issued in July 2016 that require all title insurance companies to identify and report on the natural persons behind shell companies...more

Ballard Spahr LLP

FinCEN Expands Targeting of High-End Cash Real Estate Transactions

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FinCEN has announced a major expansion and extension of its geographic targeting orders (GTOs) aimed at high-end cash buyers of real estate. This action reflects FinCEN’s continued efforts to prevent money laundering through...more

Cadwalader, Wickersham & Taft LLP

FinCEN Tightens the Screws on Money Launderers with Additional Scrutiny of High-Value Residential Real Estate Transactions

Choice real estate markets such as New York, Miami, Los Angeles, San Francisco, San Diego, and San Antonio may offer enticing amenities like buzzing nightlife or sunny beaches, but thanks to the Financial Crimes Enforcement...more

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