FinCEN’s First GTOs of 2016 Directed at U.S. Title Insurance Companies and “All Cash” Purchases


In FinCEN Targets “All Cash” Real Estate Deals in Manhattan and Miami, my colleagues Carolina Fornos, Maria Galeno, Mark Hellerer, Caroline Harcourt, and I discuss the federal Financial Crimes Enforcement Network’s (FinCEN) first Geographic Targeting Orders (GTOs) of 2016 issued on January 13. The GTOs are nyskylinedirected exclusively at U.S. title insurance companies and their subsidiaries and agents, requiring them, for a temporary period, to identify the individuals behind any entity that is used to purchase high-end residential real estate in Manhattan and Miami-Dade County, Florida, on an “all cash” basis. We discuss the immediate impact of these GTOs on these companies and what the GTOs may mean for others.

Photo:  Arturo Donate, The skyline that never sleeps… Taken July 31, 2010 – Creative Commons