On April 14, 2025, the Financial Crimes Enforcement Network (FinCEN) renewed its Geographic Targeting Orders (GTOs), continuing a strategic initiative aimed at uncovering illicit financial flows through high-end real estate transactions. These GTOs require U.S. title insurance companies to identify the natural persons behind shell companies used to purchase residential real estate in cash—effectively tightening the noose on anonymity in property deals.
Originally introduced in 2016 and extended multiple times since, the GTOs have proven to be an invaluable tool for detecting money laundering in the U.S. real estate market, which has long been a favored channel for criminals to park illicit proceeds. The latest renewal not only reinforces FinCEN’s commitment to transparency but also extends coverage to additional metropolitan areas where vulnerabilities have been identified.
Financial institutions involved in real estate financing and related services should take note. The continued expansion of GTOs signals regulatory momentum toward a permanent rule that could eliminate exemptions for certain types of transactions. This is especially relevant as FinCEN prepares to introduce rules implementing the Corporate Transparency Act (CTA), which mandates beneficial ownership disclosures.
Finassent recommends that all stakeholders in the real estate sector—title companies, realtors, attorneys, and financial service providers—proactively assess and upgrade their AML programs. Firms should review client onboarding procedures, strengthen beneficial ownership verification, and implement automated alerts for transactions involving GTO-covered jurisdictions.
In the broader compliance ecosystem, this move underscores a trend of global regulators converging on real estate as a high-risk sector. Staying ahead of such developments is no longer optional—it is foundational to risk mitigation and reputational preservation.
Source: FinCEN Renews Residential Real Estate Geographic Targeting Orders, Geographic Targeting Order Covering TITLE INSURANCE COMPANY April 14, 2025, and also see Treasury’s Financial Crimes Enforcement Network (FinCEN) Issues Southwest Border Geographic Targeting Order
Image Source: Mike, Flickr, United States Department of the Treasury
