FinCEN Issues Geographic Targeting Order for Real Estate Bought in NYC and Miami

On January 13, 2016, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) issued Geographic Targeting orders (GTO) that temporarily require certain U.S. title insurance companies to identify the natural persons behind companies used to pay “all cash” for high-end residential real estate in the Borough of Manhattan in New York City, New York, and Miami-Dade County, Florida.  FinCEN has required the information reporting on all-cash purchases – i.e., those without bank financing – that may be conducted by individuals trying to hide their assets and identity by purchasing residential properties through limited liability companies or other opaque structures.  FinCEN is requiring certain title insurance companies to identify and report the true “beneficial owner” behind a legal entity involved in certain high-end residential real estate transactions in Manhattan and Miami-Dade County.