Some Texas counties subject to special reporting requirements by FinCEN

by Kara McGregor, Senior Vice President, Independence Title

Beginning on November 21, 2023, Travis County will join Bexar, Dallas, Harris, Montgomery, Tarrant and Webb counties as part of the geographic area targeted by the Financial Crimes Enforcement Network (FinCEN) in the fight against cybercrime, money laundering, and other illicit financial activity by domestic and international criminals.

Real estate transactions are an effective way for money launderers to hide illegal funds, and FinCEN has identified specific geographic areas where real property is more likely to be targeted for illicit investment by these criminals. The agency has issued Geographic Targeting Orders (GTO’s) requiring title insurance companies doing business in those areas to perform additional due diligence and reporting on certain sale transactions.

Real estate transactions subject to additional reporting meet these criteria:

  • The sales price is over $300,000.
  • The buyer is a private entity (vs. an individual named person or a trust).
  • The buyer is paying cash, working with a hard-money lender, or seller financing.
  • The property is residential, or vacant land with immediate planned residential improvements

Primarily, the additional required information discloses the individuals behind the purchasing entity.

FinCEN is part of the US Department of Treasury, created in 1990, with the stated mission “to safeguard the financial system from illicit use, combat money laundering and promote national security.” FinCEN works with our law enforcement, financial, and regulatory communities, as well as with international partners to detect and prevent financial crimes.

Please contact your Escrow Officer with any questions related to a specific transaction, and follow for updates on this and other industry news.


Posted in: All,