The Financial Crimes Enforcement Network (FinCEN) has revised its Geographic Targeting Orders (GTOs)
that require title insurance companies to identify the individuals who use shell companies in all-cash purchases of residential real estate.
FinCEN has set its purchase amount threshold at $300,000 for all markets, a switch from an early policy that varied the threshold by location. And in a nod to the growing popularity of cryptocurrency, the agency is also requiring that covered purchases using virtual currencies be reported.
FincCEN’s GTOs cover certain counties Boston, Chicago, Dallas-Fort Worth, Honolulu, Las Vegas, Los Angeles, Miami, New York City, San Antonio, San Diego, San Francisco and Seattle.