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FinCEN Takes Aim at Real Estate Industry

Jaclyn Jaeger | January 25, 2016

Compliance officers, beware: the Financial Crimes Enforcement Network’s increasingly aggressive push to combat money laundering has entered a new phase, and this time it has its sights on high-end real estate transactions.

FinCEN, the Treasury Department’s AML enforcement agency, issued Geographic Targeting Orders (GTO) on Jan. 13 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 Manhattan, New York and Miami-Dade County, Florida. The GTOs apply to those “covered transactions” with a total purchase price in excess of $3 million in Manhattan and $1 million in Miami.

“The information gathered from the GTOs will be made available to law...

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