U.S. Treasury Renews Real Estate Transparency Orders Targeting Shell Companies in Property Deals

Title insurance companies in certain U.S. jurisdictions must continue identifying the true owners behind shell companies that use cash to purchase residential real estate, under renewed Geographic Targeting Orders (GTOs) issued by the Financial Crimes Enforcement Network (FinCEN), the anti-money laundering bureau of the U.S. Treasury.

The updated GTOs, which took effect on April 15, 2025, will remain in place through October 9, 2025. This move marks a continuation of previous GTOs implemented in 2024, aimed at curbing the use of opaque financial structures in high-value property transactions.

In a statement announcing the renewal, FinCEN emphasized the value of these measures in combating illicit activity. “The [orders] continue to provide valuable data on the purchase of residential real estate by persons possibly involved in various illicit enterprises,” the agency said. “Renewing the GTOs will further assist in tracking illicit funds and other criminal or illicit activity.”

Under the terms of the orders, title insurance companies are required to disclose the identities of individuals who ultimately own the legal entities involved in all-cash residential real estate transactions that meet a certain threshold. Title insurance, which safeguards property buyers and lenders against defects in title or claims against ownership from previous ownership disputes, is seen as a critical checkpoint for identifying ownership transparency.

The GTOs apply to a range of major metropolitan areas and counties across the United States, including locations in California, Colorado, Connecticut, Florida, Hawaii, Illinois, Maryland, Massachusetts, Nevada, New York, Texas, Washington, Virginia, and the District of Columbia.

The minimum transaction value triggering the disclosure requirement remains $300,000 for each of the covered metropolitan areas. However, the City and County of Baltimore remains an exception, with a much lower threshold of $50,000.

FinCEN acknowledged the ongoing collaboration between public and private sectors in enforcing these measures. “FinCEN appreciates the continued assistance and cooperation of title insurance companies and the American Land Title Association in protecting the real estate market from abuse by illicit actors,” it said.

A detailed list of the exact locations covered by the GTOs can be viewed here.

By fLEXI tEAM