By WWLT
In January 2016, the Financial Crimes Enforcement Network (FinCEN) began requiring title insurance companies to report information about certain high-dollar, non-financed residential property purchases in specific cities. This reporting rule was aimed at preventing real estate transactions from being used to launder money and conduct other illegal activities
Over the last decade, FinCEN has updated its rules to include more cities, and they will be updating their rules again in December 2025. Read on to find out more about FinCEN’s reporting rules and how they can affect the title insurance industry in 2025. Reach out to World Wide Land Transfer for title insurance for commercial real estate.
The first FinCEN rule that was enacted in 2016 was known as a Geographic Targeting Order (GTO), meaning it only applied to certain cities and certain transactions. Those areas were Miami-Dade County in Florida and Manhattan, New York. Any non-financed property that sold for more than $1 million was required to be reported. With many organized crime operations running in these areas, it made sense to investigate these transactions as they could potentially be used as cover to launder money from drug trafficking and other illegal activities.
Over time, the GTO was widened to include other major cities in California, Colorado, Connecticut, Florida, Hawaii, Illinois, Maryland, Massachusetts, Nevada, New York, Texas, Washington State, Virginia, and DC. The reporting threshold was also lowered to $300,000 for these areas, excluding Baltimore City and County, where the reporting threshold was lowered to $50,000. By expanding the GTO, FinCEN hoped to prevent even more illegal activity.
Beginning on December 1st, the FinCEN GTO will be expanded nationwide – including DC, Puerto Rico, and Native American lands – with no purchase price limit. That means every non-financed residential real estate purchase where the buyer is a legal entity or trust will need to be reported, including those that involve private financing, seller financing, non-institutional lending, or financing secured by collateral other than the property itself.
Although the nationwide rule has yet to take effect, those working in the title insurance industry will need to be prepared. This new requirement will require a great deal of sensitive information to be reported, so those who were not previously subject to the GTO will need to learn how to comply with reporting requirements while protecting customer data.
If you work in the title industry in a city that was already subject to FinCEN reporting requirements, very little should change for you. If, on the other hand, you will now be required to report such transactions for the first time, we suggest familiarizing yourself with all aspects of this rule. Title insurance companies can conduct training sessions to ensure their staff are up to date on the rules and requirements, and set up a framework to monitor compliance. Real estate agents and others in the real estate industry may also want to read up on the new FinCEN rules so they can inform their clients who intend to purchase real estate through non-traditional means.
Starting December 1, 2025, FinCEN’s expanded Geographic Targeting Order means that every residential real estate purchase made by a legal entity or trust without traditional institutional financing must be reported, regardless of the purchase price or location. This includes purchases using private loans, seller financing, or financing secured by assets other than the property itself. The broadened scope is designed to close loopholes that previously allowed illicit funds to enter the real estate market undetected, making compliance crucial for all title insurance companies and related professionals nationwide.
The expanded reporting requirements will create new compliance challenges, particularly for title insurance companies and agents who previously operated outside FinCEN’s geographic scope. Firms will need to establish robust data collection and verification processes to accurately capture buyer information and financing details. Because these transactions often involve sensitive personal and financial data, protecting customer privacy and maintaining data security will be top priorities. Many companies are expected to invest in staff training, updated software systems, and compliance audits to meet these heightened standards effectively.
Real estate agents, lenders, and buyers should also be aware of the new FinCEN rules to avoid surprises during transactions. Buyers using non-traditional financing through entities or trusts will now face increased scrutiny and paperwork, which may lengthen closing timelines. Agents who understand the new requirements can better prepare their clients and help them navigate these complexities. Transparent communication and early preparation will be key to ensuring smooth transactions and maintaining trust between all parties involved.
We can even provide a title insurance lender in real estate. We at World Wide Land Transfer have already been in compliance for many years now. Our team has worked with countless buyers, sellers, lenders, and others who were subject to reporting. As an industry leader, we can always ensure that we are in compliance with all FinCEN rules, and that all client information will be protected throughout the reporting process.
World Wide Land Transfer is a service-oriented PA title company with offices in Philadelphia, New York, and Washington, D.C. With a record of going above and beyond, we are trusted to close everything from complex commercial transactions to residential refinance and purchase transactions.
