FinCEN GTO

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 April 15, 2025, and ending on October 9, 2025. You can find a copy of the order below.

The renewed GTO is substantially similar to the previous GTO. Please note that reports filed under the renewed GTO should include the identifier REGTO0425 in Field 45 of the Currency Transaction Report you must submit to FinCEN. You can find the Currency Transaction Report (CTR) on the BSA E-Filing website. Please note that you must first create an account in the BSA E-Filing system. 

Key Takeaways for the new GTO:

• The GTO reporting requirement applies only when all the following criteria are met:
  • Purchase is residential real property in, inter alia:
    • 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;
• 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

• Current GTO – the Geographic Targeting Order issued by FinCEN
• FinCEN GTO Guide – provides a detailed description of the GTO reporting requirements
• FinCEN GTO Instructional Overview – provides instruction for filling out the GTO report
• Covered Transaction Worksheet – helps agents determine whether a transaction is reportable
• Information Collection Form – helps agents collect information necessary for completing the GTO report
• GTO Frequently Asked Questions – provides guidance from FinCEN regarding common questions asked about the GTO

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 SMaggiola@catictitle.com.