Today the Financial Crimes Enforcement Network (FinCEN) issued Geographic Targeting Orders (GTOs) that will temporarily require certain U.S. title insurance companies to identify the natural persons behind companies used to pay “all cash” for high-end residential real estate in the Borough of Manhattan in New York City, New York, and Miami-Dade County, Florida.  The information gathered from the GTOs will be made available to law enforcement investigators as part of FinCEN’s database and is expected to advance law enforcement’s ability to identify the natural persons involved in transactions vulnerable to abuse for money laundering.  

Beth Tractenberg, partner in Steptoe’s New York office, commented, "This requirement casts a rather broad net, which will result in a temporary loss of the ability to purchase property anonymously, which many individuals prefer to do for any number of reasons having nothing to do with money laundering."

The GTOs will be in effect for 180 days, beginning on March 1 of this year and expiring on August 27.