FinCEN has announced the expansion of its Geographical Targeting Orders (GTOs) for high-end cash buyers of real estate. The expansion is two-fold. First, FinCEN has expanded the scope of Form 8300 reportable transactions to include “funds transfers” in addition to currency, cashier’s checks, certified checks, traveler’s check, personal checks, business checks, or money orders in any form. Second, FinCEN has added real estate transactions with a total purchase price of $3,000,000 or more in the City and County of Honolulu, Hawaii. This brings the markets covered to seven metropolitan areas.

The renewed GTOs require title insurance companies to identify and report on the natural persons behind shell companies that make covered transactions. The renewed and expanded GTOs will be in effect from September 22, 2017 through March 20, 2018. FinCEN has again praised the “assistance and cooperation” of the title insurance industry in this effort.

On the same day as the GTO expansion, FinCEN published an “Advisory to Financial Institutions and Real Estate Firms and Professionals.” This Advisory is in line with our expectation that FinCEN would further expand their supervisory and enforcement activity in the real estate market, as recommended by the FATF in their 2016 Mutual Evaluation Report and highlighted in an April 12, 2016, speech by former FinCEN Director Jennifer Shasky Calvery.

Continue Reading FinCEN Continues Its Focus on Real Estate Transactions through Advisory and GTOs

We are pleased to announce that Ballard Spahr has expanded the scope of our sister blog, the award-winning CFPB Monitor.  This expanded scope reflects that we strive to deliver the breaking news and insightful analysis you need to stay agile and informed in all aspects of the world of financial regulation and enforcement.

To keep you informed of the latest developments in the rapidly evolving regulation of consumer financial services, our new Consumer Finance Monitor – spearheaded by our partner Alan Kaplinsky and our many other colleagues at Ballard Spahr’s Consumer Financial Services group – includes the firm’s flagship CFPB Monitor, which continues to provide unparalleled coverage of the Consumer Financial Protection Bureau. The Consumer Finance Monitor also features the State CFS Monitor to cover important state agency and attorney general developments, and the Federal CFS Monitor to cover important developments in consumer financial services at the FTC, the FCC, the DOJ, and the federal bank regulatory agencies (OCC, FDIC, FRB, and NCUA).

Please check out this new expanded blog, which is an excellent counterpart to our own focus on money laundering.