Financial Crimes Enforcement Network Orders Title Companies to Identify Cash Buyers

Geographic targeting orders take aim at real estate secrecy in Manhattan and Miami

By Jeff Sorg, OnlineEd Blog

stack of 100 dollar bills(January 14, 2016) – The Financial Crimes Enforcement Network (FinCEN) has issued Geographic Targeting Orders (GTO) to require certain title insurance companies to identify the natural persons behind companies used to pay all cash for high-end residential real estate in the Borough of Manhattan in New York City, New York, and Miami-Dade County, Florida. FinCEN is concerned that all-cash purchases might be conducted by individuals trying to hide their assets and identity by buying residential properties through limited liability companies (LLCs)or other opaque structures. To collect information about this potential money laundering vulnerability, FinCEN is requiring certain title insurance companies to identify and report the true “beneficial owner” behind a legal entity involved in these types of real estate transactions.


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About Jeff Sorg

Jeff Sorg holds vocational and post-secondary school instructor licenses in several states and has authored numerous real estate continuing education and pre-licensing courses. Sorg is awarded the International Distance Education Certification Center's CDEi Designation for distance education. Memberships include ARELLO (Association of Real Estate License Law Officials), REEA (Real Estate Educators Association) the National Association of REALTORS®, Oregon Association of REALTORS®, and Portland Metro Association of REALTORS®. Awards and service include REALTOR® Emeritus; Life Member award; 2020, 2021, 2022 Chairperson of the Oregon Real Estate Forms Committee; Oregon REALTORS State Director. More on request.