FinCEN GTO Expansion

July 27th, 2016 by Thomas Oates

The Financial Crimes Enforcement Network (FinCEN) recently issued an expansion to their Geographic Targeting Orders (GTO) that will temporarily require certain U.S. title insurance companies to identify the natural persons behind companies used to pay all cash for high-end residential real estate in Broward and Palm Beach Counties. This is an expansion of the previous GTO which was limited to Miami-Dade County. The US Treasury Department credits the GTO for “are helping law enforcement identify possible illicit activity and informing future regulatory approaches.” The expanded rules will require title insurance companies to collect and report personal information behind individuals and corporate buyers paying all cash for high-end residential real estate. The purchase price reporting limited is above $1,000,000 in Broward, Palm Beach and Miami-Dade. The GTO will be in effect from August 28, 2016, and continue for 180 days. FinCEN has identified all-cash high end residential purchases as particularly vulnerable to money laundering. The reporting will not be required for those purchases with external financing.

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