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  • Writer's pictureMilan Solarz-Patel

FinCEN Geographic Targeting Orders

Updated: Oct 16, 2023

FinCEN's Geographic Targeting Order covering Title Insurance Companies

Dated: April 21, 2023

The Financial Crimes Enforcement Network (FinCEN) today announced the renewal and expansion of its Geographic Targeting Orders (GTOs) that require U.S. title insurance companies to identify the natural persons behind shell companies used in non-financed (i.e., cash) purchases of U.S. residential real estate.

The terms of the GTOs are effective beginning April 25, 2023, and ending on October 21, 2023. The GTOs continue to provide valuable data on the purchase of residential real estate by persons possibly involved in various illicit enterprises. Renewing the GTOs will further assist in tracking illicit funds and other criminal or illicit activity, as well as continuing to inform FinCEN’s regulatory efforts in this sector.

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, 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, working in conjunction with its law enforcement partners, identified additional regions that present greater risks for illicit finance activity through non-financed (i.e., cash) purchases of residential real estate. Accordingly, today, FinCEN expanded the geographic coverage of the GTOs to 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. The effective period of the GTOs for purchases in these newly added areas begins on May 24, 2023. The purchase amount threshold remains $300,000 for each covered metropolitan area, with the exception of the City and County of Baltimore, where the purchase threshold is $50,000.

A copy of the GTO is available below:

Download PDF • 327KB

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