FinCEN Geographic Targeting Orders

FinCEN geographic targeting orders (or "GTOs") are specialized administrative orders issued by FinCEN under its authority under the Bank Secrecy Act.

Readers of these pages know that our primary focus is on the Corporate Transparency Act (the "CTA") and FinCEN's upcoming requirements regarding beneficial ownership reports. Nevertheless, it is helpful to understand how geographic targeting orders work and how they are different from what FinCEN will be doing under the CTA.

Under the Bank Secrecy Act, FinCEN has the authority to require parties to manage financial transactions to identify the beneficial ownership of parties to a transaction. Anyone who has opened a bank account for a company is know familiar with banks' "Know Your Customer" or "KYC" requirements. These KYC requirements are an outgrowth of FinCEN regulations applicable to banks.