The Financial Crimes Enforcement Network (FinCEN) just announced revised Geographic Targeting Orders (GTOs) that require U.S. title insurance companies to identify the natural persons behind shell companies that are used to purchase high-end residential real estate in targeted transactions. The Orders apply to seven specifically designated metropolitan areas. A GTO is an order issued by FinCEN under the Bank Secrecy Act that …
Earlier this year, the Financial Crimes Enforcement Network (FinCEN) published new rules that strengthen customer due diligence (CDD) requirements for banks, brokers or dealers in securities, mutual funds, and futures commission merchants and introducing brokers in commodities (collectively, so-called, Covered Financial Institutions). The new rules, which go into effect May 11, 2018, place new due diligence obligations on covered financial …
