Banking and Finance Law Daily Wrap Up, BANK SECRECY ACT—FinCEN extends, expands title company GTOs, (Apr 25, 2023)
Organizations Mentioned:Financial Crimes Enforcement Network
By Jacob Bielanski
The GTOs were extended through October 27.
The Financial Crimes Enforcement Network (FinCEN) has renewed its geographic targeting orders (GTOs) that require the identification of “natural persons” behind non-financed, residential real estate purchases conducted by shell companies. The GTOs were extended from April 24, 2023, to Oct. 23, 2023 (see Banking and Finance Law Daily, Oct. 27, 2022).
FinCEN renewed the GTOs that cover certain counties within the following major U.S. metropolitan areas: Boston, Chicago, Dallas-Fort Worth, Houston, Laredo, Las Vegas, Los Angeles, Miami, New York City, San Antonio, San Diego, San Francisco, Seattle, and the District of Columbia, Northern Virginia, and Maryland (DMV) area, as well as the City and County of Baltimore, the County of Fairfield, Connecticut, and the Hawaiian islands of Honolulu, Maui, Hawaii, and Kauai. FinCEN also added to the order Litchfield County in Connecticut and Adams, Arapahoe, Clear Creek, Denver, Douglas, Eagle, Elbert, El Paso, Fremont, Jefferson, Mesa, Pitkin, Pueblo, and Summit counties in Colorado. Only purchases of $300,000 or more are subject to the GTO in all metropolitan areas covered, with the exception of Baltimore County, where the threshold is $50,000.
FAQs. To assist the title companies seeking to comply with the GTOs, FinCEN also published an updated list of frequently asked questions in response to inquiries FinCEN already received.
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