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September 22, 2020

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September 21, 2020

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Update: FinCEN Issues 2019 Revised Regulations that Aim to Discover and Prevent Money Laundering

The Financial Crimes Enforcement Network (FinCEN) reissued its Geographic Targeting Order (GTO) last week, which is effective from November 12, 2019 to May 9, 2020. The reissued GTO eliminates reporting requirements for businesses regulated by the Securities and Exchange Commission (SEC), a self-regulatory organization registered with the SEC, or an entity solely owned by such business, because real estate purchases by such entities are identifiable through other business filings. Otherwise, the terms of the reissued GTO are identical to the GTO issued by FinCEN in May 2019, with the purchase amount threshold of $300,000 and the metropolitan areas covered by the GTO remaining the same.

For a more in-depth explanation of GTOs, click here.

For a copy of the November 8, 2019 GTO, click here.

© 2020 Schiff Hardin LLPNational Law Review, Volume IX, Number 318


About this Author


Marina Rabinovich counsels investors, owners, landlords, and tenants in all aspects of their real estate needs. Her pragmatic approach towards the completion of sophisticated transactions gives clients simple, yet creative, solutions to any issues that may arise. Her long-time clients know she is passionate about fighting for what is important and gets deals done.

Marina brings her no-nonsense approach to her practice. She is a strong advocate for her clients, and brings years of successful representation to each real estate deal. She uses her...

Brett Cooper Real Estate Attorney Schiff Hardin Law Firm

Brett assists with matters across a broad range of legal areas, including transactional, real estate, and trusts and estates work.

He applies diligent attention to detail to his practice as well as a calm demeanor under pressure – two skills he honed both in his pro bono work and during his time as an aspiring professional golfer.