Compliance Updates

March 2018

FinCEN Renews Order for Bexar County through Sept. 16, 2018

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

The Financial Crimes Enforcement Network (FinCEN) has again extended its Geographic Targeting Order (GTO)  issued in July 2016 and renewed in February 2017 and August 2017 (with changes) for another 180 days. The details of the order remain the same as the last GTO that ran from Sept. 20, 2017 to March 20, 2018. The extension runs through Sept. 16, 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 certain jurisdictions, including Bexar County, Texas. The threshold in Bexar County is cash deals purchased by corporate entities above $500,000.
FinCEN previously issued an advisory that provides information about money laundering risks and how to detect and report transactions to FinCEN. Additional resources are available on TLTA’s FinCEN webpage. You can also read more from ALTA.
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