In January 2016, the Treasury Department announced “geographic targeting orders” (GTOs) that will require title insurance companies and their agents to obtain representative and ultimate beneficial ownership information when a legal entity purchases residential real estate in Manhattan or Miami-Dade County with purchases prices that exceed $3 million and $1 million, respectively. It is expected that this Treasury Department effort will be expanded in the coming months or years to capture other markets and other persons involved in real estate closings and settlements.
The GT alert “U.S. Treasury Department Will Require Certain Title Insurance Companies and Their Agents To Report the Identities of the Ultimate Beneficial Owners of Entities Used To Buy Manhattan or Miami Residential Real Estate in All-Cash Purchases,” authored by Greenberg Traurig attorneys Shannon Bothwell, Jared E. Dwyer, Carl A. Fornaris, Robert J. Ivanhoe, Wendy Li, Gary A. Saul and Mark P. Schnapp, identifies requirements of the Treasury Department GTOs, the compliance risks associated therewith, and provides solutions thereto. To learn more, please click here to view the GT alert.