FinCEN reissued a Geographic Targeting Order (“GTO”) requiring title insurance companies to collect and report beneficial ownership information for certain residential real estate purchases.
The renewed GTO applies when a legal entity purchases residential real estate that:
- is in one of the specified areas (e.g., Boston, Chicago, Dallas-Fort Worth, Honolulu, Las Vegas, Los Angeles, Miami, New York City, San Antonio, San Diego, San Francisco and Seattle);
- sells for at least $300,000;
- does not involve a bank loan or similar external financing; and
- is purchased, at least in part, with currency, a cashier’s check, a certified check, a traveler’s check, a personal check, a business check, a money order, a funds transfer or virtual currency.
The GTO covers the period from May 5, 2021 to October 31, 2021. The purpose of GTOs is to identify beneficial owners of shell companies that purchase real estate without financing and may be involved in money laundering through those transactions.