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FinCEN GTOs Renewal
The Financial Crimes Enforcement Network (FinCEN) has renewed its Geographic Targeting Orders (GTOs) in an effort to identify money laundering schemes involving purchases of real estate. The new order is effective October 10, 2025, until February 28, 2028. You can find a copy of the order here.
As a reminder, FinCEN recently postponed the reporting requirements of the Anti-Money Laundering Regulations for Residential Real Estate Transfers Rule (RRE Rule), which were to take effect on December 1, 2025, until March 1, 2026. You can find a copy of the announcement here.
The renewed GTOs are substantially similar to the previous GTOs. Please note that reports filed under the renewed GTOs should include the identifier REGTO1025 in Field 45 of the Currency Transaction Report you must submit to FinCEN. You can find the Currency Transaction Report (CTR) on the BSA E-Filing website. Please note that you must first create an account in the BSA E-Filing system.
CATIC has a number of resources available on its website to assist you in the GTOs reporting process, including:
· FinCEN GTO Guide – provides a detailed description of the GTOs reporting requirements
· FinCEN GTO Instructional Overview – provides instruction for filling out the GTOs report
· Covered Transaction Worksheet – helps agents determine whether a transaction is reportable
· Information Collection Form – helps agents collect information necessary for completing the GTOs report
· GTO Frequently Asked Questions – provides guidance from FinCEN regarding common questions asked about the GTOs
Should you have any questions, please contact Erin Cabelus, VP, Compliance and Regulatory Counsel, at ecabelus@catic.com.
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