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Home » Blog » FinCEN renews transparency orders for title companies
Real Estate

FinCEN renews transparency orders for title companies

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Last updated: 2025-04-15 19:52
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The U.S. Department of the Treasury‘s Financial Crimes Enforcement Network (FinCEN) has renewed its Geographic Targeting Orders (GTOs), extending efforts to combat money laundering through anonymous real estate purchases.

The renewed orders, which are effective Tuesday and run through Oct. 9, 2025, require title insurance companies to identify the true, natural owners behind shell companies involved in non-financed residential property purchases.

The initiative is part of a broader push to track illicit funds that are potentially tied to criminal activity, FinCEN said.

“These orders continue to yield vital insights into how bad actors exploit the U.S. real estate market to launder illicit money,” its announcement stated.

GTOs will apply to select counties and metro areas across 14 jurisdictions: California, Colorado, Connecticut, Florida, Hawaii, Illinois, Maryland, Massachusetts, Nevada, New York, Texas, Washington, Virginia and Washington, D.C.

The purchase price threshold remains at $300,000 for most locations, except in Baltimore, where the threshold is set at $50,000. No changes have been made to the geographic scope of the orders since the last renewal.

FinCEN said that the ongoing cooperation of title insurance firms and the American Land Title Association (ALTA) in advancing transparency have been vital in “protecting the real estate market from abuse by illicit actors.”

In March, the Treasury Department announced that it will not be handing down penalties stemming from violations of the beneficial ownership information (BOI) reporting rule as part of the Corporate Transparency Act.

According to a press release, the Treasury will not enforce any penalties or fines associated with the beneficial ownership information reporting rule under existing regulatory deadlines. It also will not enforce any penalties or fines against U.S. citizens or domestic reporting companies (or their beneficial owners) after the forthcoming rule changes take effect.

ALTA noted that title insurance companies were already exempt from the BOI reporting requirement due to the rule’s exemption for state-licensed insurance producers. But ramifications could still be felt in the title sector.

FinCEN first issued a Notice of Proposed Rulemaking in late 2021 that required companies to report beneficial ownership information.

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