FinCEN Renews Real Estate Geographic Targeting Orders

October 17, 2024

The Financial Crimes Enforcement Network (FinCEN) on Oct. 15 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 GTOs are effective through April 14, 2025.
  • 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 ALTA 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 August 2024, FinCEN issued a final rule requiring certain industry professionals to report information to FinCEN about non-financed transfers of residential real estate to a legal entity or trust. This nationwide reporting framework will replace the GTOs and goes into effect on Dec. 1, 2025. 

ALTA had asked for a one-year implementation period at a minimum. ALTA shares the goal of protecting the U.S. real estate market from money laundering and intends to work collaboratively with FinCEN. ALTA’s focus is to help reduce the impact on small businesses and the cost of the regulation. Click here to read ALTA’s comment letter to FinCEN. 

Any questions about the orders should be directed to FinCEN’s Regulatory Support Section at [email protected].


Contact ALTA at 202-296-3671 or [email protected].