August 2018 JD Supra

A GTO is a Geographic Targeting Order issued by the Financial Crimes Enforcement Network (FinCEN) under the Bank secrecy Act (BSA) for a specific geographic area.  FinCEN has issued GTOs requiring certain U.S. title insurance companies to record and report information, including beneficial ownership, about legal entities used to make “non-financed” purchases of high-value residential real estate in seven major U.S. geographic areas with different dollar thresholds: