Monthly Archives: December 2018

FinCEN Extends and Expands Orders to Identify Beneficial Owners of All-Cash Real Estate Purchases

We reported previously¬†that the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”) had issued a Geographic Targeting Orders (GTOs”)¬†originally in July 2016 ordering title insurance companies to identify the actual owners of limited liability companies used in all-cash purchases of high-end real estate ($3 million and greater) in certain cities.¬† FinCEN has now announced an extension… Read more »