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Laws and Rules:

On April 29, 2021, 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 all-cash purchases of residential real estate.  The terms of this Order are effective beginning May 5, 2021 and ending October 31, 2021.  The purchase amount threshold remains $300,000 for each covered metropolitan area.  Honolulu continues to be subject to the GTOs.

On November 15, 2018, FinCEN set the purchase amount threshold, which previously varied by city, at $300,000 for each covered metropolitan area. FinCEN also 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.  Affected title insurance companies must have procedures in place to ensure compliance with the GTOs; see the GTOs for details.

Any questions about the Orders should be directed to FinCEN’s Regulatory Support Section at [email protected].

A copy of the GTO is available here.

Frequently asked questions regarding the GTOs are available here.