- 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 of the GTOs for six months and three major expansions of the program. First, the GTOs now cover not only the counties comprising New York City, but other counties that include cities such as Boston, Chicago, Dallas-Fort Worth, Honolulu, Las Vegas, Los Angeles, Miami, San Antonio, San Diego, San Francisco and Seattle. Second, the threshold has been reduced from $3 million to $300,000. Finally, the identification of beneficial owners covers any business entity of which the person owns directly or indirectly 25% of the equity.
