US FinCEN Continues to Renew and Expand Real Estate GTOs
On October 26, 2022, the Financial Crimes Enforcement Network (“FinCEN”) renewed and expanded geographic targeting orders (“GTOs”) for certain “all-cash” purchases of residential real estate (“October 2022 GTOs”).1 The October 2022 GTOs remain in effect until April 24, 2023, but are likely to be renewed based on FinCEN’s prior practices.
Since 2016, FinCEN has issued a series of increasingly expansive GTOs that require US title insurance companies to identify the natural persons behind legal entities (US […]