On May 15, 2019, the Financial Crimes Enforcement Network (FinCEN) renewed its Geographic Targeting Orders (GTOs) that require US title insurance companies to identify natural persons behind shell companies that purchase residential real-estate in amounts of $300,000 or more in cash.

The renewed targeting order maintains coverage to include twelve major metropolitan areas including Boston; Chicago; Dallas-Fort Worth; Honolulu; Las Vegas; Los Angeles; Miami; New York City; San Antonio; San Diego; San Francisco; and Seattle. In addition to this, the purchase amount threshold, which previously varied by city, is now set at $300,000 for each covered metropolitan area. FinCEN is also requiring that covered purchases using virtual currencies be reported.

The May 14, 2019 GTO can be found here.

A FAQ relating to the GTO can be found here.

Adam Witmer

Adam Witmer is a speaker, author, and founder of the Compliance Cohort. Adam has taught hundreds of seminars and training sessions to thousands of bankers throughout the United States and teaches on all areas of regulatory compliance. Adam has written five e-books that he never published, hit a grizzly bear while driving in a National Park, and is an award winning photographer and musician (though he no longer takes photos nor plays any instruments). In his spare time, Adam can be found kayaking on the lake, doing taekwondo with his kids, working on his (project) house, or spending time with his family.

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