FinCEN Geographic Targeting Orders (GTOs) Extended Again (March 2018 update)

I previously wrote about the the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) “Geographic Targeting Orders” (GTOs) here (August 2016), here (February 2017), and here (August 2017 update).

The GTOs were updated again beginning March 21, 2018, and extended to September 16, 2018, unless superseded, and except as is provided in Section III.C of the Orders (regarding retention of records).

The GTOs require that title insurance underwriters and their agents report information about certain residential real estate transactions with a sale price of $1,000,000 or more in Miami-Dade, Broward and Palm Beach Counties.**  The purpose of the GTOs is to help FinCEN and other federal agencies identify potential money laundering in certain real estate transactions. For more information about reporting requirements, see my update post from August 2017.

A  blank FinCEN Form 8300 form can be downloaded here in fillable .pdf format.  A sample Form 8300 with the necessary information completed can be found here.

FAQs for the GTOs can be found here.   Any other questions about the Orders should be directed to the FinCEN Resource Center at 800-767-2825.  Each of the major title insurance underwriters will also be able to provide information about the GTOs and the underwriter’s requirements for compliance with the GTOs.

**  Note:  This blog is concerned primarily with South Florida real estate issues, but the renewed GTOs include the following major U.S. geographic areas:  (1) all boroughs of New York City; (2) Miami-Dade County and the two counties immediately north (Broward and Palm Beach); (3) Los Angeles County; (4) three counties comprising part of the San Francisco area (San Francisco, San Mateo, and Santa Clara counties); (5) San Diego County; and (6) the county that includes San Antonio, Texas (Bexar County).  The monetary thresholds for each geographic area can be found in this table on FinCEN’s website.