On 4/29/2021, the Financial Crimes Enforcement Network (FinCEN) announced the renewal of a set of Geographic Targeting Orders (GTOs) that have been renewed several times now, the last renewal being in November 2020. These GTOs require U.S. title insurance companies to identify the natural persons behind shell companies used in all-cash purchases of residential real estate and only apply to title companies in certain metropolitan areas. The purchase amount threshold remains $300,000 for each covered metropolitan area.

The renewed Order is effective from May 5, 2021 through October 31, 2021 and cover 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.

The GTOs can be found here.

A set of FAQs that accompany the GTOs 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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