On July 27, 2016, the Financial Crimes Enforcement Network of the U.S. Department of the Treasury (FinCEN) issued a press release announcing new Geographic Targeting Orders (GTOs) applicable to certain U.S. title insurance companies and their subsidiaries and “agents” (collectively, the Targeted Title Insurance Companies). The new GTOs go well beyond those that were initially issued in January 2016 that were geographically limited to certain residential real estate transactions in Manhattan and Miami-Dade County. The new GTOs require Targeted Title Insurance Companies to obtain information on the ultimate beneficial owners of certain entities buying residential real estate in six U.S. metropolitan markets.
To learn more about this topic, please see GT Alert “Insurance Companies and Their Agents To Report the Ultimate Beneficial Owners of Entities Used To Buy Residential Real Estate in All-Cash Purchases in Six Metropolitan Areas, Including all of New York City, South Florida and Portions of California and Texas.”