Since January 2016, the Financial Crimes Enforcement Network (FinCEN), required title companies to collect and report beneficial ownership information on certain real estate transactions. These Geographic Targeting Orders apply to all title insurers, their subsidiaries and agents of (“Covered Business”).

The Financial Crimes Enforcement Network (FinCEN) on April 17, 2024 renewed its Geographic Targeting Orders (GTO) that require U.S. title insurance companies to identify the natural persons behind shell companies used in non-financed purchases of residential real estate.
  • The terms of the GTO are effective through Oct. 15, 2024.
  • FinCEN renewed the GTOs that cover certain counties and major U.S. metropolitan areas in California, Colorado, Connecticut, Florida, Hawaii, Illinois, Maryland, Massachusetts, Nevada, New York, Texas, Washington, Virginia, and the District of Columbia.
  • The purchase amount threshold remains $300,000 for each covered metropolitan area, except for the city and county of Baltimore, where the purchase threshold is $50,000.
Advisory and Background Documents

FinCEN’s Advisory

FinCen Advisory - August 22, 2017

Geographic Targeting Order

GTO Phase 18

ALTA’s Background Article

The Hunt for Dark Money

Information Collection Form

FinCEN Information Collection Form

View the FinCEN GTO Fact Sheet

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