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ARTICLE · 20 OCTOBER 2025

FinCEN Renews Geographic Targeting Order

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On October 9, 2025, the Financial Crimes Enforcement Network ("FinCEN") issued a renewal of its Geographic Targeting Order ("GTOs"), which require U.S. title insurance companies...

United StatesGovernment, Public Sector
Kelly A. Lenahan-Pfahler
Kelly A. Lenahan-Pfahler
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On October 9, 2025, the Financial Crimes Enforcement Network ("FinCEN") issued a renewal of its Geographic Targeting Order ("GTOs"), which require U.S. title insurance companies, including their subsidiaries and agents, to collect, retain, and report specified information regarding certain non-financed residential real estate transactions involving legal entities. The new GTO is effective from October 10, 2025 through February 28, 2026.

Access the new GTO here. Read FinCEN's press release here. Read FinCENs FAQs about the GTOs here. This is a topic on which we previously have blogged extensively.

Context and Regulatory Background

The renewal of the GTOs follows FinCEN's September 30, 2025 announcement postponing implementation of its forthcoming Anti-Money Laundering Regulations for Residential Real Estate Transfers Rule ("RRE Rule") until March 1, 2026. During this interim period, FinCEN states that the GTOs are intended to maintain transparency in residential

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