FinCEN Extends Targeting Orders

On May 15, 2019, the Financial Crimes Enforcement Network (FinCEN) renewed its Geographic Targeting Orders (GTOs) that require US title insurance companies to identify natural persons behind shell companies that purchase residential real-estate in amounts of $300,000 or more in cash.   

The renewed targeting order maintains coverage to include twelve major metropolitan areas including Boston; Chicago; Dallas-Fort Worth; Honolulu; Las Vegas; Los Angeles; Miami; New York City; San Antonio; San Diego; San Francisco; and Seattle.  In addition to this, the purchase amount threshold, which previously varied by city, is now set at $300,000 for each covered metropolitan area. FinCEN is also requiring that covered purchases using virtual currencies be reported.

The May 14, 2019 GTO can be found here.

A FAQ relating to the GTO can be found here.

Example of Unfair UDAAP Violation

Example of Unfair UDAAP Violation

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