Topic
Geographic Targeting Orders
16 published works
Money Laundering Watch
FinCen Renews its Focus on Minnesota
On August 11, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) renewed its Geographic Targeting Order (“GTO”) Imposing Recordkeeping and Reporting Requirements on Certain Financial Institutions…
Money Laundering Watch
FinCEN’s Southwest Border Geographic Targeting Order Faces Challenges in Texas and Southern California
In March, we wrote about the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issuing a Geographic Targeting Order (GTO) aimed to combat Mexican-based drug cartels. The GTO signals Treasury’s…
Subject to Inquiry
FinCEN Narrows Focus on Southwest Border
By John Adams, Elissa Baur, Katherine Richardson, V. Kathleen Dougherty, Jeffrey M. Hanna
In the last few weeks, the Financial Crimes Enforcement Network (FinCEN) has circulated several instructions focusing on money services businesses operating in the southwest United States, answering the current Administration’s…
Financial Services Perspectives
How the Trump Administration’s War on Cartels Will Reshape the Financial Sector
By Jonathan "Jack" Harrington, Leah M. Campbell, Gabriella E. Alonso, John Thomas Mostellar III
On March 11, 2025, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) aimed at disrupting drug trafficking and money laundering along the southwestern border.…
Money Laundering Watch
Real Estate GTO Renewed and Expanded
FinCEN announced yesterday that, once again, it is extending the Geographic Targeting Order, or GTO, which requires U.S. title insurance companies to identify the natural persons behind so-called "shell companies"…
Money Laundering Watch
FinCEN Again Extends Real Estate GTOs
The Financial Crimes Enforcement Network ("FinCEN") has, once again, extended its Geographic Targeting Order ("GTO") requiring U.S. title insurance companies to identify the natural persons behind legal entities used in…
Money Laundering Watch
Filling Gaps: Defending American Security from Kremlin Aggression Act of 2019 Would Expand Use of Geographic Targeting Orders
"Sanctions Bill from Hell" Targets Real Estate Deals On February 13, 2019, Sen. Lindsay Graham (R – S.C.) introduced S.482 – the Defending American Security from Kremlin Aggression Act of…
International Trade Law
FinCEN Issues Revised GTOs Including Lower Purchase Thresholds and Virtual Currencies
By Carlton Greene, Allegra Flamm
On November 15, 2018, FinCEN issued revised Geographic Targeting Orders (GTOs), once more expanding its scrutiny of “all-cash” purchases (i.e., those without bank loans or other external financing) in the…
Tax Controversy Report
FinCEN Remains Mum on Details Regarding New Geographic Targeting Orders
We previously reported that the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) had quietly extended its Geographic Targeting Orders directed at the luxury residential real estate market for another six…
Real Estate & Construction
FinCEN Issues Revised Geographic Targeting Orders Focusing on Shell Companies Purchasing Luxury Properties in 7 Major Metropolitan Areas
Today the Financial Crimes Enforcement Network (FinCEN) announced the issuance of revised Geographic Targeting Orders (GTOs) that require U.S. title insurance companies to identify the natural persons behind shell companies used…