Tuesday, November 27, 2018

New Geographic Targeting Order

New Geographic Targeting Order

A new Geographic Targeting Order was released Nov. 15..

The press release and the GTO itself are available here:

·         Financial Crimes Enforcement Network, FinCEN Reissues Real Estate Geographic Targeting Orders and Expands Coverage to 12 Metropolitan Areas (Press Release Nov. 15, 2018), available at https://www.fincen.gov/news/news-releases/fincen-reissues-real-estate-geographic-targeting-orders-and-expands-coverage-12

·         Financial Crimes Enforcement Network, Geographic Targeting Order Covering TITLE INSURANCE COMPANY (Nov. 15, 2018), available at https://www.fincen.gov/sites/default/files/shared/Real%20Estate%20GTO%20GENERIC_111518_FINAL%20508.pdf

For some additional commentary, see also Samuel Rubenfeld, U.S. Expands Coverage of Real Estate Anti-Money Laundering Program (Wall Street Journal, Nov. 15, 2018), available at https://www.wsj.com/articles/u-s-expands-coverage-of-real-estate-anti-money-laundering-program-1542322224

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