Geographic targeting orders (GTO) and FinCEN Consulting brought money laundering issues in the real estate business to light. They stressed the significance of providing SARs if a buyer or seller is suspected of money laundering. As a result, the processes were ensured to be integrated into existing AML / CFT compliance programs. As a result, businesses should already have Customer Due Diligence and Transaction Monitoring systems in place to identify customers and beneficial owners, and these aims should be aligned with GTO for efficiency and accuracy.

What is GTO?

The Financial Crimes Enforcement Network (FinCEN) uses geographic targeting orders (GTO) to discover money laundering and other criminal actions through real estate purchases. For many years, real estate acquisitions have been a powerful technique for money laundering, particularly through shell corporations, and this GTO tries to break this down. The Bank Secrecy Act (BSA) has given the GTO the jurisdiction to determine these actions.

Furthermore, the GTO, an order mandating the Commission to report on this process when you bring greater value transactions from a designated geographical area in U.S. domestic financial institutions, was enacted. GTOs must identify persons behind corporations who pay for high-quality real estate in the two selected marketplaces as part of FinCEN’s ongoing anti-money laundering operations. Geographic Targeting Orders were issued by the Financial Crimes Enforcement Network (FinCEN) in January 2016.

The Financial Crimes Enforcement Network (FinCEN) originally announced GTO in January 2016, and this revised order was said to be valid between November 12, 2019, and May 9, 2020. Finally, FinCEN expanded its Geographic Targeting Order (“GTO”), which requires title insurance providers to report residential property sales in select large metropolitan areas, on May 8, 2020.

The geographic zones in which the GTO was permitted with a $ 300,000 monetary threshold did not alter following the past session. As a result, no additional jurisdiction was added to GTOs’ existing reach. This new model was identical to the November 2019 GTOs. FinCEN extended the GTOs for another six months on May 8, 2020. GTO requested that insurance companies in certain geographic areas declare their purchases of residential homes in metropolitan centers.

How does GTO work?

Geographic targeting orders solve the issue of anonymously purchasing high-end residential homes. An insurance provider is required by GTO to notify unfinished housing sales ($300,000 or more) to legal entity buyers within 30 days following closing. The purchaser must include ownership information for the legal entity at a 25% level. The insurance company must use documentary resources to confirm the identification of the rights holders and their agents.

Previously limited to money-related activities, Geographic targeting orders now cover money and transactions involving “funds.” If institutions fail to comply with GTO, FinCEN may levy penalties or individual prison sentences ranging from 5 to 10 years. GTOs decide which enterprises must comply with record-keeping and reporting requirements. GTOs are regulated for a limited time, which was up to 60 days in the 2000s, but are now extended to 180 days by the US Patriot Act. FinCEN may also extend this time in certain circumstances.

Requirements for GTO

FinCEN firms must be submitted by insurance firms in their comprehensive transactions within 30 days of the closing date. This form should include the following information:

• The identification of the person in charge of representing the recipient
• Documents that prove the individual’s identity
• Documents establishing the identification of the recipient’s beneficial owners as well as the individual
• The purchase amount and the date of the transaction
• The residential property’s address