FinCEN Extends Program to Identify Beneficial Owners of Real Estate Entities to November

The Financial Crimes Enforcement Enforcement Network (“FinCEN”) of the U.S. Treasury has extended to November its program to require title insurance agencies in certain cities to collect and report to it the beneficial owners of legal entities used to purchase real estate.  The “Geographic Targeting Order” applies to acquisitions of residential real estate in certain cities (i.e., New York, Boston, Chicago, Los Angeles, Dallas-Fort Worth, Honolulu, Las Vegas, Miami, San Diego, San Francisco and Seattle) where the sales price is at least $300,000, the purchase is not made under a bank loan or similar financing and the purchase is made at least in part in cash (or the equivalent, like a cashier’s check or a personal check).