FinCEN has issued Geographic Targeting Orders (“GTOs”) requiring “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 New York City, Miami-Dade County Florida, Bexar County, Texas, Broward and Palm Beach Counties in Florida, and Los Angeles, San Diego, San Francisco, San Mateo and Santa Clara Counties in California.

The GTOs have been further extended for 180 days beginning on September 27, 2017 by a new GTO issue by FinCEN on August 22, 2017. The new GTO also expands the requirements to include the purchase of real estate by an entity in the City and County of Honolulu in Hawaii for a total purchase price of for $3,000,000 or more. In addition, transactions within the scope of the GTO are now required to be reported to FinCEN when “such purchase is made, at least in part, using currency, or a cashier’s check, a certified check, a traveler’s check, a personal check, a business check, or a money order in any form, or a funds transfer”. The GTO is posted at https://www.fincen.gov/sites/default/files/shared/Real%20Estate%20GTO%20Order%20-%208.22.17%20Final%20for%20execution%20-%20Generic.pdf.