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All-Cash, No Title Insurance Purchases Evade FinCEN Real-Estate Rules

By Valentina Pasquali

The U.S. Treasury Department still lacks complete visibility into “all-cash” real-estate acquisitions made anonymously through shell companies, say sources. Since March 2016, the department’s Financial Crimes Enforcement Network, or FinCEN, has required title insurance firms to identify each individual owning 25 percent or more of a legal entity used to purchase high-end residences in Miami and New York in cash only and without a bank loan. FinCEN subsequently extended the expiration date of the geographic targeting order, or GTO, three times and expanded it to five additional metropolitan areas considered entry points for potentially illicit funds. In August, U.S. lawmakers...

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