U.S. Treasury Order Affects Title Companies in Bexar, Tarrant or Dallas Counties

Requirements went into effect Aug. 28, 2016 and were updated effective May 16, 2019. The order has been extended through Nov. 11, 2019.

In an effort to identify money-laundering schemes, the U.S. Treasury Department Financial Crimes Enforcement Network (FinCEN) has issued an updated Geographic Targeting Order (GTO) requiring all title insurance companies to identify the natural persons behind shell companies used in all-cash purchases of real estate. The purchase amount threshold remains $300,000 for each covered metropolitan area. In Texas, these reporting requirements are limited to transactions occurring in Bexar, Tarrant or Dallas counties.

GTO Details (updated May 16, 2019)

FinCEN Press Release re: Revised GTO
Geographic Targeting Order (GTO)
FinCEN Frequently Asked Questions (FAQs)


ALTA Article Regarding FinCEN’s Revised GTO

This information is being provided by TLTA for educational and reference purposes only, and is not intended to represent the only approach to any particular issue. This information should not be construed as legal, financial or business advice from or on behalf of TLTA, and users should consult their own legal counsel and subject-matter experts to ensure that any policies adopted or actions taken meet the requirements unique to their company.