The Financial Crimes Enforcement Network renewed its residential real estate Geographic Targeting Orders, continuing to require US title insurance companies to identify the natural persons behind shell companies used in non-financed purchases of residential real estate in covered areas. The renewed orders take effect on October 10, 2025 and are set to expire on February 28, 2026. The renewed GTOs continue to cover certain counties and major metropolitan areas in California, Colorado, Connecticut, Florida, Hawaii, Illinois, Maryland, Massachusetts, Nevada, New York, Texas, Washington, Virginia, and the District of Columbia, with no changes to jurisdictional coverage. The purchase price threshold remains USD 300,000 for each covered metropolitan area, except for the City and County of Baltimore where the threshold is USD 50,000. FinCEN tied the GTO end date to the Anti-Money Laundering Regulations for Residential Real Estate Transfers Rule, whose reporting requirements were previously postponed to March 1, 2026.
Financial Crimes Enforcement Network 2025-10-09
Financial Crimes Enforcement Network renews residential real estate Geographic Targeting Orders effective October 10 2025 through February 28 2026
The Financial Crimes Enforcement Network has renewed its Geographic Targeting Orders (GTOs) for residential real estate, requiring US title insurance companies to identify individuals behind shell companies in non-financed purchases in specified areas. Effective October 10, 2025, the GTOs maintain existing jurisdictional coverage and purchase price thresholds, except for Baltimore, where the threshold is USD 50,000. The orders are linked to the Anti-Money Laundering Regulations for Residential Real Estate Transfers Rule, with reporting requirements postponed to March 1, 2026.