On May 8, 2020, the Financial Crimes Enforcement Network (FinCEN) renewed its Geographic Targeting Orders (GTOs) that require U.S. title insurance companies to obtain and verify identifying information for the natural persons behind shell companies used to make all-cash purchases of residential real estate with values equal to or greater than $300,000.  The GTOs only apply in certain metropolitan counties within the following nine states: California, Florida, Hawaii, Illinois, Massachusetts, Nevada, New York, Texas, and Washington.  No new jurisdictions were added to those covered by previous GTOs, and the reissuance mirrors the November 2019 GTOs.  Covered transactions include purchases made using currency, cashier’s checks, certified checks, traveler’s checks, personal checks, business checks, money orders, funds transfers, or virtual currencies.

FinCEN also provided related FAQs, which are identical to those released in the November 8, 2019 renewal.

These latest GTOs went into effect on May 10, 2020 and remain in effect until November 5, 2020.

Under the Bank Secrecy Act, the Director of FinCEN may issue GTOs that impose temporary recordkeeping and reporting requirements on one or more domestic financial institutions or nonfinancial trades or businesses in a geographic area within the U.S.  These orders can be in effect for up to 180 days and can be renewed thereafter following a finding that the circumstances justifying the original GTO continue to exist.