FINCEN ISSUES GEOGRAPHIC TARGETING ORDERS CONCERNING ALL CASH DEALS FOR REAL ESTATE ACQUISITIONS IN NEW YORK CITY AND MIAMI.

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On January 13, 2016, the Financial Crimes Enforcement Network (“FinCEN”) issued Geographic Targeting Orders (“GTOs”) that temporarily require certain US title insurance companies to identify the natural persons behind companies used in “all cash” deals for high­ end residential real estate in Manhattan and Miami­Dade County, Florida.[1]

[1]          See https://www.fincen.gov/news_room/nr/html/20160113.html (last accessed February 16, 2016).