FinCEN Renews Real Estate Geographic Targeting Orders
April 15, 2025
The Financial Crimes Enforcement Network (FinCEN) on April 14 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 Oct. 9, 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.
Any questions about the orders should be directed to FinCEN’s Regulatory Support Section at [email protected].
FinCEN Anti-Money Laundering Rule and Virtual Bootcamp
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. This rule goes into effect Dec. 1, 2025. ALTA will host a two-day virtual bootcamp to help title and settlement companies prepare for the rule. Click here for more information and to register.
Contact ALTA at 202-296-3671 or [email protected].