FinCEN Renews and Expands Real Estate Geographic Targeting Orders

October 27, 2022

On Oct. 26, the Financial Crimes Enforcement Network (FinCEN) renewed and once again expanded its Geographic Targeting Orders (GTOs) 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 GTOs are effective through April 24, 2023.

FinCEN, working in conjunction with our law enforcement partners, identified additional regions that present greater risks for illicit finance activity through non-financed purchases of residential real estate. 

The expanded geographic coverage of the GTOs now includes counties encompassing the Texas cities of Houston and Laredo. The effective period of the GTOs for purchases in these newly added areas begins on Nov. 25, 2022.

FinCEN renewed the GTOs that cover certain counties within the following major U.S. metropolitan areas:

  • Boston
  • Chicago
  • Dallas-Fort Worth
  • Las Vegas
  • Los Angeles
  • Miami
  • New York City
  • San Antonio
  • San Diego
  • San Francisco
  • Seattle
  • Washington, D.C.
  • Northern Virginia and Maryland (DMV) area
  • City and County of Baltimore
  • County of Fairfield, Conn.
  • Hawaiian Islands of Honolulu, Maui, Hawaii and Kauai 

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. 

FinCEN appreciates the continued assistance and cooperation of title insurance companies and the American Land Title Association in protecting real estate markets from abuse by illicit actors.

According to FinCEN, the GTOs continue to provide valuable data on the purchase of residential real estate by persons possibly involved in various illicit enterprises. Renewing the GTOs will further assist in tracking illicit funds and other criminal or illicit activity, as well as inform FinCEN’s future regulatory efforts in this sector, according to FinCEN.

Any questions about the orders should be directed to FinCEN’s Regulatory Support Section at

Contact ALTA at 202-296-3671 or