U.S. Treasury Issues Advisory and Geographic Targeting Order as Congress Considers Entity Transparency Bills

On August 22, 2017, the Financial Crimes Enforcement Network (FinCEN) announced the issuance of revised Geographic Targeting Orders (GTOs) that require U.S. title insurance companies to identify the natural persons behind shell companies used to pay for luxury residential real estate in seven metropolitan areas.[1]  After the recent enactment of the Countering America’s Adversaries through Sanctions Act, FinCEN is revising the GTOs to include a broader range of transactions, such as transactions involving wire transfers.  FinCEN also extended the GTOs to include transactions conducted in the City and County of Honolulu, Hawaii.[2]