FinCEN Renews Geographic Targeting Orders
October 10, 2025
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) renewed 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 GTOs go into effect Oct. 10.
On Sept. 30, FinCEN postponed reporting requirements of the Anti-Money Laundering Regulations for Residential Real Estate Transfers Rule (RRE Rule) until March 1. In light of the rule’s reporting requirements, the residential real estate GTOs will expire on Feb. 28.
The renewed GTOs continue to 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. No changes have been made to jurisdictional coverage since the last issuance of these GTOs. The purchase price threshold likewise remains $300,000 for each covered metropolitan area, with the exception of the City and County of Baltimore, where the purchase price threshold is $50,000.
FinCEN appreciates the continued assistance and cooperation of title insurance companies and the American Land Title Association in protecting the real estate market from abuse by illicit actors.
Any questions about the GTOs should be directed to fincen.gov/contact.
A copy of the order is available here.
Frequently asked questions regarding these GTOs are available here.
Contact ALTA at 202-296-3671 or [email protected].