Today, the Financial Crimes Enforcement Network (FinCEN) announced, effective August 28, 2016 and continuing for 180 days, it is expanding its earlier Geographic Targeting Orders (GTO) requiring information about the natural persons behind shell companies used to purchase high-end residential real estate for “all cash.” FinCEN has been collecting this data on Manhattan and Miami-Dade County, Florida since January and believes it is “on the right track” in its anti-money laundering (AML) efforts and investigation of possible money laundering using real estate deals. It will collect this information in California for San Francisco, San Mateo and Santa Clara counties; Los Angeles County; and San Diego County. It will expand to all boroughs of New York City and to Broward and Palm Beach counties in Florida. Bexar county in Texas, that includes San Antonio is also included. Monetary thresholds for each area identified are provided in FinCEN’s announcement. Title insurance companies are required to comply with the GTO and provide the information.

Additional Source: FinCEN’s First GTOs of 2016 Directed at U.S. Title Insurance Companies and “All Cash”