The US Financial Crimes Enforcement Network is temporarily requiring American title insurance companies to identify the natural persons behind shell companies used to pay 'all cash' for expensive residential real estate in six major metropolitan areas.

FinCEN has done this with the issuance of Geographic Targeting Orders or GTOs. All-cash purchases are purchases without bank financing, i.e. made without a bank loan or other similar form of external financing. The new GTOs consist of:

• all boroughs of New York City (price threshold $1½ million, but $3 million for Manhattan);
• Miami-Dade County and the two counties immediately north of it (Broward and Palm Beach) (price threshold $1 million);
• Los Angeles County and three counties comprising part of the San Francisco area (San Francisco, San Mateo, and Santa Clara counties) in California (price threshold $2 million);
• San Diego County in California (price threshold $2 million); and
• Bexar County, the county that includes San Antonio in Texas (price threshold $½ million).

Title insurance is a form of indemnity insurance predominantly found in the United States which insures against financial loss from defects in title to real property and from the invalidity or unenforceability of mortgage loans. FinCEN believes it to be highly conducive to money laundering. The director of FinCEN may issue an order that imposes certain additional recordkeeping and reporting requirements on one or more domestic financial institutions or nonfinancial trades or businesses in a geographic area, in accordance with 31 USC s5326(a); 31 CFR s1010.370; and Treasury Order 180-01. The reports, on Form 8300, must contain information about the identity of the individual primarily responsible for representing the purchaser (including passport or driver's licence); information about the purchaser's identity; information about the beneficial owner and information about the transaction itself.