FinCEN Renews Geographic Targeting Orders

​The Financial Crimes Enforcement Network (FinCEN) today announced the renewal of its Geographic Targeting Orders (GTOs) that require U.S. title insurance companies to identify the natural persons behind shell companies used in non-financed purchases of residential real estate.  No changes have been made to jurisdictional coverage since the last issuance of these GTOs.

The purchase price threshold likewise remains $300,000 for each covered metropolitan area, with the exception of the City and County of Baltimore, where the purchase price threshold is $50,000.

The terms of the GTOs are effective beginning April 15, 2025, and ending on October 9, 2025. Per FinCEN, the GTOs continue to provide valuable data on the purchase of residential real estate by persons possibly involved in various illicit enterprises. Renewing the GTOs will further assist in tracking illicit funds and other criminal or illicit activity.

The GTOs cover certain counties and major U.S. metropolitan areas in California, Colorado, Connecticut, Florida, Hawaii, Illinois, Maryland, Massachusetts, Nevada, New York, Texas, Washington, Virginia, and the District of Columbia. 

Any questions about the Orders should be directed to FinCEN’s Regulatory Support Section at [email protected].

A copy of the GTO is available here. Frequently asked questions regarding these GTOs are available here.