FinCEN Renews Real Estate Geographic Targeting Orders

April 18, 2024

The Financial Crimes Enforcement Network (FinCEN) on April 17 renewed its Geographic Targeting Orders (GTO) that requires 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, Virgina, 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. 

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 GTO 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.

FinCEN began issuing Geographic Targeting (GTOs) orders in January 2016 requiring title insurance companies to file reports and maintain records concerning all-cash purchases of residential real estate above a certain threshold in select metropolitan areas of the United States. 

In February 2024, FinCEN issued a notice of proposed rulemaking for an anti-money laundering regulation in the residential real estate sector. The comment period for the proposed rule closed on April 16. FinCEN said it will renew the GTOs while it reviews and considers all of the comments submitted. Click here to read ALTA’s comment letter to FinCEN. ALTA’s letter focused on recommended changes to help reduce the compliance burden on title and settlement companies and to make the rule more effective.

FinCEN Director Andrea Gacki will speak at the 2024 ALTA Advocacy Summit on May 7.

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

Contact ALTA at 202-296-3671 or