FinCEN GTO Update

CATIC Title has received notice that the Financial Crimes Enforcement Network (FinCEN) will be renewing the Geographic Targeting Order (GTO) in an effort to identify money laundering schemes involving purchases of real estate. This new order is effective October 22, 2023 until April 18, 2024. You can find a copy of the order below.

The renewed GTO features substantive changes to prior GTOs, including the addition of Massachusetts Counties of Bristol, Essex, Norfolk, and Plymouth and Florida Counties of Hillsborough, Pasco, Pinellas, Manatee, Sarasota, Charlotte, Lee, and Collier to the areas covered by the GTO.  The effective period of the GTOs for purchases in newly added areas begins on November 21, 2023.

Key Takeaways for the new GTO:

  • The GTO reporting requirements apply only when all the following criteria are met:
    • Purchase is residential real property in, inter alia:
      • Suffolk, Middlesex, Bristol, Essex, Norfolk, or Plymouth Counties, Massachusetts;
      • Fairfield or Litchfield Counties, Connecticut;
      • The Boroughs of Brooklyn, Queens, Bronx, Staten Island, or Manhattan in New York City, New York;
      • Miami-Dade, Broward, Palm Beach, Hillsborough, Pasco, Pinellas, Manatee, Sarasota, Charlotte, Lee, or Collier Counties, Florida;
      • Cook County, Illinois
    • Purchase is made by a Legal Entity, defined as a corporation, limited liability company, partnership, or other similar business entity that is not a U.S. publicly traded company (note that purchases by individuals and/or trusts do not trigger the GTO reporting requirement);
    • Purchase price is $300,000 or more;
    • Purchase is made without a bank loan or other similar form of external financing; and
    • The purchase is made, at least in part, using currency or a cashier’s check, certified check, traveler’s check, personal check, business check, money order in any form, funds transfer (including wire transfer), or virtual currency
  • The terms of the renewed GTO are NOT confidential

During the effective period, you are expected to comply with the terms of the order, including requirements to collect certain information and report said information to FinCEN and CATIC Title.

CATIC Title has provided a number of resources to assist you in the process. These tools include:

It is important to note that failure to comply with this order may result in civil and/or criminal penalties.

Should you have any questions, please contact Steve Maggiola, CATIC Title’s Senior Vice President & Counsel, at

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