CLTA FinCEN Resource Page

What is FinCEN?

The mission of the Financial Crimes Enforcement Network is to safeguard the financial system from illicit activity, counter money laundering and the financing of terrorism, and promote national security through strategic use of financial authorities and the collection, analysis, and dissemination of financial intelligence.  

FinCEN carries out its mission by receiving and maintaining financial transactions data; analyzing and disseminating that data for law enforcement purposes; and building global cooperation with counterpart organizations in other countries and with international bodies.

FinCEN’s Geographic Targeting Orders (GTOs) require U.S. title insurance companies to identify the natural persons behind shell companies used in non-financed purchases of residential real estate. There are purchase amount thresholds, with a few exceptions. The GTOs cover certain counties within the following 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. The GTOs are currently in effect through October 9, 2025.

Geographical Targeting Orders

---

​FinCEN’s Anti-Money Laundering in Residential Real Estate Rule (Rule) is different from the GTO’s. The new Rule requires new information and collection reporting and is expected to impact all CLTA members handling sale transactions involving buyer entities or trusts without involving FDIC-insured lenders. The Rule applies nationwide, has no purchase price thresholds, offers limited transactional exemptions, and mandates the collection and reporting of significant amounts of information. This new Rule will now take effect March 1 and CLTA members are strongly encouraged to begin preparations now.

Anti-Money Laundering in Residential Real Estate Rule