On January 13, 2016 FinCEN 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 the Borough of Manhattan in New York City, New York, and Miami-Dade County Florida”.

On July 22, 2016, FinCEN issued an Order extending the requirements to include real estate in Bexar County, Texas, Broward and Palm Beach Counties in Florida, The Boroughs of Brooklyn, Queens, the Bronx and Staten Island in New York City, and Los Angeles, San Diego, San Francisco, San Mateo and Santa Clara Counties in California. The GTOs, as previously extended, would have expired on February 23, 2017. FinCEN has extended the requirements for one hundred eighty days beginning February 24.

Get more information on FinCEN’s news release posted here.