FinCEN Reissues, Expands Real Estate Geographic Targeting Orders

The Financial Crimes Enforcement Network on April 29 reissued and expanded its geographic targeting orders requiring U.S. title insurance companies in specified areas to identify the individuals behind companies used to conduct high-end, all-cash real estate transactions. The orders are effective April 30, 2022 to Oct. 26, 2022.

FinCEN renewed orders covering Bexar, Tarrant and Dallas counties in Texas; Miami-Dade, Broward and Palm Beach counties in Florida; all boroughs of New York City; San Diego, Los Angeles, San Francisco, San Mateo and Santa Clara counties in California; Honolulu County in Hawaii; Clark County in Nevada; King County in Washington; Suffolk and Middlesex counties in Massachusetts; and Cook County in Illinois.

Meanwhile, FinCEN issued new orders covering the Washington-Baltimore area, encompassing Anne Arundel, Baltimore, Howard, Montgomery and Prince George’s counties plus Baltimore city in Maryland; Arlington and Fairfax counties plus Alexandria, Falls Church and Fairfax cities in Virginia; and the District of Columbia. The orders also expanded to include Fairfield County in Connecticut and the Hawaii counties of Hawaii, Maui and Kauai, which combined with Honolulu cover virtually all land and residences in the state. The purchase amount threshold at which the new and renewed orders apply remains $300,000, except in the city and county of Baltimore, where it is $50,000.