On 3rd December, the National Law Review published an article saying that on November 15th FinCEN issued its 6th Geographic Targeting Order (GTO) aimed at preventing money laundering in all-cash residential real estate purchases made by legal entities.  Since promulgating its first GTO in 2016, FinCEN has issued revisions and extensions approximately every 6 months.  These latest revisions significantly broaden prior regulations by decreasing the threshold dollar amount, including sales involving cryptocurrencies, and expanding the list of targeted geographic areas.  The GTO applies to all transfers of residential real property purchased without a bank loan by a legal entity for $300,000 or more, using, at least in part, currency or a cashier’s cheque, a certified cheque, a traveller’s cheque, a personal cheque, a business cheque, a money order in any form, a funds transfer, or virtual currency.

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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