FinCEN Reissues Geographic Targeting Order For 12 Metropolitan Areas

CW
Cadwalader, Wickersham & Taft LLP

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Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
The GTO covers the period from May 5, 2021 to October 31, 2021.
United States Real Estate and Construction
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FinCEN reissued a Geographic Targeting Order ("GTO") requiring title insurance companies to collect and report beneficial ownership information for certain residential real estate purchases.

The renewed GTO applies when a legal entity purchases residential real estate that:

  • is in one of the specified areas (e.g., Boston, Chicago, Dallas-Fort Worth, Honolulu, Las Vegas, Los Angeles, Miami, New York City, San Antonio, San Diego, San Francisco and Seattle);
  • sells for at least $300,000;
  • does not involve a bank loan or similar external financing; and
  • is purchased, at least in part, with currency, a cashier's check, a certified check, a traveler's check, a personal check, a business check, a money order, a funds transfer or virtual currency.

The GTO covers the period from May 5, 2021 to October 31, 2021.

Primary Sources

  1. FinCEN Press Release: FinCEN Reissues Real Estate Geographic Targeting Orders for 12 Metropolitan Areas
  2. FinCEN GTO: Title Insurance Companies

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