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Geographic Targeting Orders

16 published works

  1. Money Laundering Watch

    FinCen Renews its Focus on Minnesota

    By Emily Friedman

    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…

  2. Money Laundering Watch

    FinCEN’s Southwest Border Geographic Targeting Order Faces Challenges in Texas and Southern California

    By Matthew T. Smith

    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…

  3. 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…

  4. 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.…

  5. Money Laundering Watch

    Real Estate GTO Renewed and Expanded

    By Peter D. Hardy

    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"…

  6. Money Laundering Watch

    FinCEN Again Extends Real Estate GTOs

    By Peter D. Hardy

    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…

  7. Money Laundering Watch

    Filling Gaps: Defending American Security from Kremlin Aggression Act of 2019 Would Expand Use of Geographic Targeting Orders

    By Terence M. Grugan

    "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…

  8. 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…

  9. Tax Controversy Report

    FinCEN Remains Mum on Details Regarding New Geographic Targeting Orders

    By Matthew D. Lee

    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…

  10. Real Estate & Construction

    FinCEN Issues Revised Geographic Targeting Orders Focusing on Shell Companies Purchasing Luxury Properties in 7 Major Metropolitan Areas

    By Matthew D. Lee

    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…