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The Financial Crimes Enforcement Network ("FinCEN")
renewed a Geographic Targeting Order ("GTO")
requiring title insurance companies to collect and report
beneficial ownership information for certain real estate
purchases.
The reissued 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 or a cashier's check, certified check, traveler's
check, personal check, business check, money order, funds transfer
or virtual currency.
The GTO will be effective from May 16, 2019 to November 11,
2019.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
