The Financial Crimes Enforcement Network (FinCEN) recently renewed and expanded its Geographic Targeting Order (GTO) requiring title companies to identify natural persons behind shell companies used in all-cash purchases of residential real estate. The GTOs since inception have focused on non-financed, residential real estate transactions in certain markets. The current GTO is effective April 25, 2023, until October 21, 2023. The current order has been expanded to include new jurisdictions including counties in Colorado-- Adams, Arapahoe, Clear Creek, Denver, Douglas, Eagle, Elbert, El Paso, Fremont, Jefferson, Mesa, Pitkin, Pueblo, or Summit, and Litchfield County, in Connecticut.
NAR will continue to monitor anti-money laundering and counter terrorist financing matters, and will continue to provide updates.