Aug. 22, 2017

FinCEN Renews Order for Bexar County, With Changes

Order for Seven Major Areas Includes Cash Deals Purchased by Corporate Entities; Also Covers Wire Transfers

The Financial Crimes Enforcement Network (FinCEN) Geographic Targeting Order (GTO) first issued in July 2016 and renewed in February 2017 has been renewed again for 180 days. It will go into effect Sept. 22, 2017, and end on March 20, 2018. This order requires title insurers and their agents to identify the names of individuals involved in corporations, LLCs and other legal entities that make all-cash purchases for high-end residential real estate in Bexar County. The threshold in Bexar County is cash deals purchased by corporate entities above $500,000.

Three changes have been made to this GTO:

  1. Wire transfers: Due to the new Russia sanctions law, the new GTO will cover transactions without a bank loan where all or a portion of the purchase price is paid in currency, check or funds transfer.
  2. New jurisdiction: The city and county of Honolulu, Hawaii have been added.
  3. New effective date: This GTO will take effect Sept. 22, 2017, and will stay effective for the following six months.

Watch TLTA's free webinar "FinCEN Geographic Targeting Order: What You Need to Know Before Closing a Deal in Bexar County." Additional resources are available on TLTA's FinCEN webpage.

View FinCEN's press release, advisory, FAQs on the renewed GTO and Form 8300.

TLTA will continue to keep members informed about this development. If you have questions, please contact Aaron Day, Director of Government Affairs and Counsel, at 512.879.2881 or