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Laws and Rules:


FinCEN Geographic Targeting Order Applicable to Title Insurance Companies

On October 20, 2023, the Financial Crimes Enforcement Network (“FinCEN”) of the U.S. Treasury Department renewed its Geographic Targeting Orders (“GTOs”) that require U.S. title insurance companies to identify the natural persons behind shell companies used in non‑financed purchases of residential real estate.

The terms of the renewed GTOs are effective beginning October 22, 2023, and end on April 18, 2024.  The purchase amount threshold remains $300,000 for each covered metropolitan area.  The GTOs continue to apply to the islands of Oahu, Maui, Hawaii, and Kauai.

Affected title insurance companies must have procedures in place to ensure compliance with the GTOs; see the GTOs for details.


  • On November 15, 2018, FinCEN added the requirement to report covered purchases using virtual currencies.
  • Title insurance companies in Honolulu have been subject to the GTOs since August 22, 2017.  The islands of Maui, Hawaii Island, and Kauai were added to the GTOs in April 2022.


  • Direct questions about the GTOs to FinCEN’s Regulatory Support Section at [email protected].
  • The current GTO is available here.
  • Frequently asked questions regarding the GTOs are available here.