Well worth a read (I always read the Miami Herald when in Panama – it even has a decent crossword!)

The Miami Herald on 18th July carried an article about what had happened since 2016, when the US Treasury Department imposed a temporary transparency rule (known as a GTO) on Miami-Dade County and Manhattan.  It says that, according to a new research paper, anonymous cash buyers stopped buying homes — at least using the method targeted by regulators – with, in Miami-Dade, a 95% drop in how much cash shell companies and other corporate entities spent on homes (from 29% to 2% of the sales).  The rule does not apply to transactions that involve a mortgage.  The article says that officials want to see the rules made permanent and expanded nationwide, but the study also reveals the difficulties regulators face in catching those determined to worm their money into the US financial system. Overall sales in the area did not fall much.  Alternate methods of purchase now being used to hide buyers could include using stand-ins who nominally control the property on behalf of the real owner or employing other corporate vehicles like trusts or other means to evade the reporting requirements by, for instance, taking out a small mortgage.  Strangely, shell companies also stopped buying homes with cash in many other places around the nation, even though those areas were not targeted, the study found, perhaps anticipating an extension of the rule – and FinCEN has since expanded the rule to other markets in Florida, New York, Texas, California and Hawaii.  In May, FinCEN dropped the reporting threshold from $1 million to $100,000 and extended the reporting requirement to trusts.  Also, FinCEN has stopped publicising such changes, to avoid alerting the bad guys.

The study from the University of Miami and referred to in the article is available at –

A copy of the current, updated, Geographical Targeting Order (GTO) can be found at –

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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