On Feb. 23, 2017, the Financial Crimes Enforcement Network of the U.S. Department of the Treasury (FinCEN) extended by an additional six months its existing Geographic Targeting Orders (GTOs) that require U.S. title insurance companies, their subsidiaries and agents (collectively, the Title Insurance Companies) to identify the natural persons behind shell companies used to pay
U.S. Treasury Department Expands its ‘Real Estate GTOs’ to Require Title 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
By Greenberg Traurig on
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…
Carl Fornaris and Shannon Bothwell Presented on the New FinCen Real Estate GTO
By Greenberg Traurig on
Posted in Events
Greenberg Traurig’s Carl Fornaris, Shareholder, and Shannon Bothwell, Of Counsel, participated in the FIBA and STEP presentation titled “The New FinCen Real Estate GTO: What You Need to Know” on Feb. 9 at Greenberg Traurig’s Miami office. The program addressed the geographic targeting orders (GTOs) issued by the Financial Crimes Enforcement Network of the U.S.…
Manhattan and Miami Residential Real Estate Sales – What Are the New Treasury Department Anti-Money Laundering Requirements All About?
By Greenberg Traurig on
Posted in Financial Regulation, Real Estate
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…
FinCEN Issues Second South Florida GTO in Less Than Three Months
By Greenberg Traurig on
Posted in Financial Crimes Enforcement Network
Today, the Financial Crimes Enforcement Network (FinCEN), working in conjunction with U.S. Internal Revenue Service – Criminal Investigation (IRS-CI) and the United States Attorney’s Office for the Southern District of Florida, issued a Geographic Targeting Order (GTO) for Miami-Dade and Broward counties. The GTO applies to check cashing business and requires check cashers to keep…