On Thursday, January 14, 2016 we posted U.S FinCEN Will Track Secret Buyers of Luxury Real Estate in Manhattan and Miami where we discussed that the Financial Crimes Enforcement Network (FinCEN) on January 13, 2016 issued a Geographic Targeting Orders (GTO) that will temporarily require certain U.S. title insurance companies to identify the natural persons behind companies used to pay "all cash" for high-end residential real estate in the Borough of Manhattan in New York City, New York, and Miami-Dade County, Florida.
The initiative is part of a broader federal effort to increase the focus on money laundering in real estate. Treasury and federal law enforcement officials said they were putting greater resources into investigating luxury real estate sales that involve shell companies like limited liability companies, often known as L.L.C.s; partnerships; and other entities.
Now The US Treasury's Financial Crimes Enforcement Network (FinCEN) has renewed six so-called 'temporary geographic targeting orders' that require US title insurance companies to name the natural persons behind shell companies used to buy luxury residential property for cash in major metropolitan areas.
FinCEN says that 30 per cent of transactions covered by the orders – in New York City, Miami, Los Angeles, San Francisco, San Diego and San Antonio – involve a beneficial owner or purchaser representative that is also the subject of a previous suspicious activity report.
The GTOs renewed include the following major U.S. geographic areas:
The monetary thresholds for each geographic area can be found in this table. A sample GTO, which becomes effective for 180 days beginning on February 24, 2017, is available here.
The GTOs renewed include the following major U.S. geographic areas:
- all boroughs of New York City;
- Miami-Dade County and the two counties immediately north (Broward and Palm Beach);
- Los Angeles County;
- three counties comprising part of the San Francisco area (San Francisco, San Mateo, and Santa Clara counties);
- San Diego County; and
- the county that includes San Antonio, Texas (Bexar County).
The monetary thresholds for each geographic area can be found in this table. A sample GTO, which becomes effective for 180 days beginning on February 24, 2017, is available here.
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