Yesterday the Financial Crimes Enforcement Network (FinCEN) announced Geographic Targeting Orders (GTOs) that will temporarily require US title insurance companies to identify the natural persons behind shell companies used to pay “all cash” for high-end residential real estate in six major metropolitan areas.
FinCEN first issued GTOs for the borough of Manhattan in New York City and for Miami-Dade County, Florida in January of this year. The GTOs announced yesterday include (1) all boroughs of New York City; (2) Miami-Dade County, Broward County, and Palm Beach County in Florida; (3) Los Angeles County, California; (4) three counties comprising part of the San Francisco area (San Francisco, San Mateo, and Santa Clara counties); (5) San Diego County, California; and (6) the county that includes San Antonio, Texas (Bexar County). The monetary thresholds for each geographic area range from $500,000 for Bexar County to $3 million for the borough of Manhattan.
FinCEN also released a sample GTO, which becomes effective for 180 days beginning on August 28.