The Financial Crimes Enforcement Network (FinCEN), an entity within the U.S. Treasury, renewed its geographic targeting orders (GTOs) requiring 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 were effective Oct. 16 and will end on April 14, 2025. The GTOs continue to provide valuable data on the purchase of residential real estate by persons possibly involved in various illicit enterprises, FinCEN stated. Renewing the GTOs will further assist in tracking illicit funds and other criminal or illicit activity, as well as continuing to inform FinCEN’s regulatory efforts in this sector.

According to the release:

• FinCEN renewed the GTOs that cover certain counties and major metropolitan areas in California, Colorado, Connecticut, Florida, Hawaii, Illinois, Maryland, Massachusetts, Nevada, New York, Texas, Washington, Virginia, and the District of Columbia.
• The purchase price threshold remained at $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 real estate markets from abuse by illicit actors,” the agency said.

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.

Ballard Spahr Partner Richard Andreano shared with settlement service providers what they need to know about this new rule during RESPRO’s fall session in Washington, D.C. Check back with RESPA News for highlights from this discussion coming soon.