The Financial Crimes Enforcement Network (FinCEN) renewed its Geographic Targeting Orders (GTOs) requiring U.S. title insurance companies to identify the natural persons behind shell companies used in non-financed purchases of residential real estate. The renewed GTOs apply from April 15, 2025 through October 9, 2025 and 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. Jurisdictional coverage is unchanged from the prior issuance, and the purchase price threshold remains USD 300,000 in covered areas, except in the City and County of Baltimore where the threshold is USD 50,000.
Financial Crimes Enforcement Network 2025-04-14
Financial Crimes Enforcement Network renews Geographic Targeting Orders for title insurers to report beneficial owners in all-cash residential real estate purchases
The Financial Crimes Enforcement Network (FinCEN) has renewed its Geographic Targeting Orders (GTOs) requiring U.S. title insurance companies to identify the natural persons behind shell companies in non-financed residential real estate purchases. The GTOs, effective from April 15 to October 9, 2025, maintain jurisdictional coverage and a purchase price threshold of USD 300,000, except in Baltimore where it is USD 50,000.