As expected, on May 8, 2020, the Financial Crimes Enforcement Network (“FinCEN”) reissued its Geographic Targeting Orders (“GTOs”) requiring U.S. title insurance companies to identify the natural persons behind legal entities used in purchases of residential real estate performed without a bank loan or similar form of external financing. The monetary threshold remains at $300,000, and the nine districts remain the same. The GTOs cover purchases involving virtual currency as well as “fiat” currency, wires, personal or business checks, cashier’s checks, certified checks, traveler’s checks, a money order in any form, or a funds transfer.
No new jurisdictions were added to the previously existing coverage of the GTOs:
- California: San Diego, Los Angeles, San Francisco, San Mateo and Santa Clara Counties
- Florida: Miami-Dade, Broward and Palm Beach Counties
- Hawaii: City and County of Honolulu
- Illinois: Cook County
- Massachusetts: Suffolk and Middlesex Counties
- Nevada: Clark County
- New York: Boroughs of Brooklyn, Queens, Bronx, Staten Island and Manhattan
- Texas: Bexar, Tarrant and Dallas counties
- Washington: King County
The reissuance was identical to the November 2019 GTOs.
FinCEN also released a response to Frequently Asked Questions (“FAQs”), which is identical to the FAQs issued in May 2019.