On April 29, 2022, the Financial Crimes Enforcement Network (FinCEN) announced the renewal and expansion of Geographic Targeting Orders (GTOs) that require U.S. title insurance companies to identify the natural persons behind shell companies used in all-cash purchases of residential real estate. FinCEN renewed the GTOs for certain major U.S. metropolitan areas AND expanded the geographic coverage of the GTOs to parts of the District of Columbia, Northern Virginia, and Maryland (DMV) metropolitan area. The purchase threshold is $300k for each covered metropolitan area, with the exception of Baltimore City and Baltimore County, where the purchase threshold is $50,000.
The terms of the GTOs are effective beginning April 30, 2022 and ending on October 26, 2022. A copy of the GTO is available here. Frequently asked questions regarding the GTOs are available here.
If you have specific questions about this Alert or would like more information about our Residential Real Estate Settlements Team or our general real estate transactions and litigation practice, please contact the Practice Group Chair at settlements@shulmanrogers.com.
CONTACT
Matthew D. Alegi
Ryan D. Malet
Danielle M. Dolch
David M. Kochanski
Marc D. Lipman
Erin August
