​FinCEN Renews and Expands Real Estate Geographic Targeting Orders
- Effective October 10, 2025

Since January 2016, FinCEN has required title companies to gather and report information about the true owners behind certain real estate deals. These rules, called Geographic Targeting Orders, apply to all title insurers, along with their subsidiaries and agents (also referred to as “Covered Businesses”).

On September 30, 2025, FinCEN announced a postponement of the reporting requirements of the reporting requirements of the Anti-Money Laundering Regulations for Residential Real Estate Transfers Rule (RRE Rule) until March 1, 2026.  In light of the RRE Rule’s reporting requirements, the residential real estate GTOs will expire on February 28, 2026, with the GTOs continuing to provide valuable data on the purchase of residential real estate by persons possibly involved in various illicit enterprises.

These renewed GTOs continue to 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. 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.

Informational Links:

• FinCEN Renews Real Estate GTOs (Effective October 10, 2025)
• FinCEN GTO Frequently Asked Questions (October 9, 2025)
• CLTA Informational Graphic re: GTOs - Intended for title companies to distribute to real estate professionals with which they are in contact, this infographic quickly breaks down the basics of the FinCEN Geographical Targeting Orders .
• CLTA Titlecast - Episode 21:  Coping with the Geographic Targeting Orders (GTOs) (September 2022)