The Financial Crimes Enforcement Network (FinCEN) has announced the extension and expansion of its Geographic Targeting Orders (GTOs). These orders require U.S. title insurance companies to identify the individuals behind companies involved in cash purchases of residential real estate without financing.
The renewed GTOs are in effect from October 22, 2023, to April 18, 2024. They play a vital role in collecting data on the acquisition of residential real estate by individuals potentially engaged in illicit activities. Renewing these orders will aid in tracking suspicious funds and criminal activities, supporting FinCEN’s regulatory efforts in this sector.
The GTOs cover specific counties in major U.S. metropolitan areas, including Boston, Chicago, Dallas-Fort Worth, Houston, Las Vegas, Los Angeles, Miami, New York City, San Antonio, San Diego, San Francisco, Seattle, Denver, the District of Columbia, Maryland, Northern Virginia, the City and County of Baltimore, as well as counties in Connecticut and Hawaii. FinCEN, in collaboration with law enforcement, identified additional regions at higher risk of illicit financial activity through cash real estate purchases. Consequently, the geographic coverage of the GTOs has been expanded to include counties in Massachusetts, Florida, and Texas.
The effective period of the GTOs for these newly added areas starts on November 21, 2023. The purchase threshold remains at $300,000 for most covered metropolitan areas, with an exception for the City and County of Baltimore, where the threshold is $50,000.
FinCEN acknowledges the ongoing cooperation of title insurance companies and the American Land Title Association in safeguarding real estate markets against potential misuse by illicit actors.

