FinCEN Extends and Expands the Reach of its Real Estate “Geographic Targeting Orders”

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Friday, August 12, 2016
Bruce Zagaris
                On July 27, 2016, the Financial Crimes Enforcement Network (FinCEN) announced Geographic Targeting Orders (GTO) that will temporarily require U.S. title insurance companies to identify the natural persons behind shell companies used to pay “all cash” for high-end residential real estate in six major metropolitan areas.  FinCEN expressed concern that all-cash purchases (i.e., ones without bank financing) may be conducted by individuals trying to hide their assets and identity by buying residential properties through limited liability companies or other opaque structures.  FinCEN issued similar GTOs earlier this year for transactions in Manhattan and Miami-Dade County, Florida.  The new GTO will expand upon the valuable information received from the initial GTOs.