On July 27th, the Financial Crimes Enforcement Network (FinCEN) announced Geographic Targeting Orders (“GTO”) that will temporarily require U.S. title insurance companies to identify the natural persons behind entities used to pay all cash transactions (i.e. no bank financing) for high-end residential real estate in six metropolitan areas.  Those areas are:

  1. All boroughs of New York City;
  2. Miami-Dade County, Florida;
  3. Broward County, Florida;
  4. Palm Beach County, Florida;
  5. Los Angeles County, California;
  6. San Francisco County, California;
  7. San Mateo County, California;
  8. Santa Clara County, California;
  9. San Diego County, California; and
  10. San Antonio, Texas (Bexar County).

The monetary threshold varies between areas.  For example, it is $3 million in Manhattan, $1.5 million in the remaining NYC boroughs, $1 million in the affected counties of Florida and $2 million in those in California.  The GTOs are effective for 180 days beginning August 28, 2016.

This is an extension of the initiative launched in January by the Treasury Department to begin identifying and tracking buyers of high-end properties made in all-cash purchases in an effort to track down money laundering through real estate and identify individuals hiding assets or engaged in illicit activities.  Manhattan, New York and Miami-Dade County, Florida were the specific focus of the initiative when first launched.