On 13 August, Cadwalader Cabinet published an article saying that the US Government Accountability Office has recommended that FinCEN undertake additional procedures to implement and evaluate the effectiveness of GTO for certain real estate transactions between 2016 and 2020. These GTO require title insurance companies to collect and report beneficial ownership information for certain all-cash real estate purchases in Manhattan and Miami, initially, and later for other New York City boroughs and certain other cities. The recommendations are contained in a report to Congress, and they include those flowing from conclusions that FinCEN failed to properly share data and failed to monitor compliance by the insurance companies.

The report is 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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