FinCEN Renews Geographic Targeting Orders

May 12, 2020

The Financial Crimes Enforcement Network (FinCEN) renewed its Geographic Targeting Orders (GTOs) requiring U.S. title insurance companies to identify the natural persons behind shell companies used in all-cash purchases of residential real estate.

These orders are effective through Nov. 5, 2020. The renewed GTOs are identical to the November 2019 GTOs.  The purchase amount threshold remains $300,000 for each covered metropolitan area.

According to FinCEN, the GTOs continue to provide valuable data on the purchase of residential real estate by persons possibly involved in various illicit enterprises. Reissuing the GTOs further assists tracking illicit funds and other criminal or illicit activity, as well as inform FinCEN’s future regulatory efforts in this sector, the agency said in a release.

Today’s GTOs cover certain counties within the following major U.S. metropolitan areas:  Boston; Chicago; Dallas-Fort Worth; Honolulu; Las Vegas; Los Angeles; Miami; New York City; San Antonio; San Diego; San Francisco; and Seattle.

FinCEN also applauded the continued assistance and cooperation of the title insurance companies and ALTA in protecting the real estate markets from abuse by illicit actors.

ALTA has developed several tools to help members comply with the order.

Companies with questions can email FinCEN at .

Frequently asked questions regarding these GTOs are available here.

Contact ALTA at 202-296-3671 or