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FinCEN Geographic Targeting Orders Expanded and Extended

FinCEN – the Financial Crimes Enforcement Network of the U.S. Treasury – has extended and expanded its geographic targeting orders (“GTOs”) applicable to title insurance companies. Prior geographic targeting orders have required title insurance companies to identify and report to FinCEN the natural persons behind shell companies used in non-financed purchases of residential real estate.

FinCEN’s latest ruling takes effect October 27, 2022 and ends on April 24, 2023.

FinCEN extended its existing GTO through April 24, 2023 for following jurisdictions: Boston; Chicago; Dallas-Fort Worth; 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 also added the following new jurisdictions: Houston, Texas and Laredo, Texas.

FinCEN stated in its announcement that it was working in conjunction with our law enforcement partners and was adding these jurisdictions because they presented greater risks for illicit finance activity through non-financed purchases of residential real estate.

The effective period of the GTOs for purchases in these newly added areas begins on November 25, 2022. 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.

About The Author

Jonathan Wilson is the co-founder of FinCEN Report Company with 31 years of experience in corporate, M&A and securities matters. He is the author of The Corporate Transparency Act Compliance Guide (to be published by Lexis Nexis in the summer of 2023) and the Lexis Practical Guidance Practice Note on the Corporate Transparency Act.