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FinCEN Renews Geographic Targeting Orders on Certain Residential Real Estate Purchases for Additional Six Months

By Caroline Brown, Carlton Greene, Erik Woodhouse & Tyler Brown on May 15, 2020
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On May 8, 2020, the Financial Crimes Enforcement Network (FinCEN) renewed its Geographic Targeting Orders (GTOs) that require U.S. title insurance companies to obtain and verify identifying information for the natural persons behind shell companies used to make all-cash purchases of residential real estate with values equal to or greater than $300,000.  The GTOs only apply in certain metropolitan counties within the following nine states: California, Florida, Hawaii, Illinois, Massachusetts, Nevada, New York, Texas, and Washington.  No new jurisdictions were added to those covered by previous GTOs, and the reissuance mirrors the November 2019 GTOs.  Covered transactions include purchases made using currency, cashier’s checks, certified checks, traveler’s checks, personal checks, business checks, money orders, funds transfers, or virtual currencies.

FinCEN also provided related FAQs, which are identical to those released in the November 8, 2019 renewal.

These latest GTOs went into effect on May 10, 2020 and remain in effect until November 5, 2020.

Under the Bank Secrecy Act, the Director of FinCEN may issue GTOs that impose temporary recordkeeping and reporting requirements on one or more domestic financial institutions or nonfinancial trades or businesses in a geographic area within the U.S.  These orders can be in effect for up to 180 days and can be renewed thereafter following a finding that the circumstances justifying the original GTO continue to exist.

 

Photo of Caroline Brown Caroline Brown

Caroline E. Brown is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s White Collar & Regulatory Enforcement and International Trade groups and the steering committee of the firm’s National Security Practice. She provides strategic advice to…

Caroline E. Brown is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s White Collar & Regulatory Enforcement and International Trade groups and the steering committee of the firm’s National Security Practice. She provides strategic advice to clients on national security matters, including anti-money laundering (AML) and economic sanctions compliance and enforcement challenges, investigations, and cross border transactions, including review by the Committee on Foreign Investment in the United States (CFIUS) and the Committee on Foreign Investment in the U.S. Telecommunications Services Sector (Team Telecom).

Caroline brings over a decade of experience as a national security attorney at the U.S. Departments of Justice and the Treasury. At the U.S. Department of Justice’s National Security Division, she worked on counterespionage, cybersecurity, and counterterrorism matters and investigations, and gained unique insight into issues surrounding data privacy and cybersecurity. In that role, she also sat on both CFIUS and Team Telecom and made recommendations to DOJ senior leadership regarding whether to mitigate, block, or allow transactions under review by those interagency committees. She also negotiated, drafted, and reviewed mitigation agreements, monitored companies’ compliance with those agreements, and coordinated and supervised investigations of breaches of those agreements.

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Photo of Carlton Greene Carlton Greene

Carlton Greene is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering…

Carlton Greene is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering (AML) laws and regulations, export controls, and anti-corruption/anti-bribery laws and regulations. Carlton is the former chief counsel at FinCEN (the Financial Crimes Enforcement Network), the U.S. AML regulator responsible for administering the Bank Secrecy Act.

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Photo of Erik Woodhouse Erik Woodhouse

Erik Woodhouse is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and Financial Services groups, where he provides in-depth experience and practical solutions on sensitive economic sanctions and anti-money laundering matters, informed by his

…

Erik Woodhouse is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and Financial Services groups, where he provides in-depth experience and practical solutions on sensitive economic sanctions and anti-money laundering matters, informed by his experience in private practice and in government at the Department of the Treasury and the Department of State.

Erik works with U.S. and foreign clients operating across borders on all aspects of these regimes, including developing and assessing compliance programs, advising on complex statutory and regulatory requirements, and leading companies through internal and government investigations. He has worked with major manufacturing and tech companies with global operations, multinational banks, investment funds and other financial services firms, and digital assets and virtual currency companies, collaborating with Crowell’s cross-disciplinary team that comprises former senior regulators, federal prosecutors, and in-house counsel.

Prior to joining Crowell, Erik served as Deputy Assistant Secretary of State for Counter Threat Finance and Sanctions at the Department of State, where he played a key role in the Department’s policy development and implementation related to all U.S. country-based sanctions programs and a range of global programs. Erik worked with counterparts across the executive branch to establish and implement new sanctions programs, coordinated U.S. sanctions policy with foreign governments, and engaged with private sector stakeholders on a range of U.S. sanctions priorities. Erik’s prior government experience also includes service at the Department of the Treasury’s Office of International Affairs.

Earlier in his career, Erik worked as a project finance attorney and litigator, as a law clerk for the Honorable M. Margaret McKeown of the U.S. Court of Appeals for the Ninth Circuit, and as a research fellow at Stanford University’s Program on Energy & Sustainable Development.

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Photo of Tyler Brown Tyler Brown

Tyler Brown is an associate in the firm’s Washington, D.C. office, where he is a member of the Government Contracts Group. Tyler’s practice focuses on various government contracts issues, including government and internal investigations related to the False Claims Act, Procurement Integrity Act…

Tyler Brown is an associate in the firm’s Washington, D.C. office, where he is a member of the Government Contracts Group. Tyler’s practice focuses on various government contracts issues, including government and internal investigations related to the False Claims Act, Procurement Integrity Act, and other civil and criminal matters; suspension and debarment proceedings; federal subpoena responses; and bid protests before the U.S. Government Accountability Office and the U.S. Court of Federal Claims.

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  • Posted in:
    Real Estate & Construction
  • Blog:
    International Trade Law
  • Organization:
    Crowell & Moring LLP
  • Article: View Original Source

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