This memo supplements the original FinCEN Geographic Targeting Order dated August 11th 2016 and Supplemental Memo dated August 19th 2016. National Investors Title Insurance Company ("NITIC") has been issued a Geographical Targeting Order ("Order") by the Director of the Financial Crimes Enforcement Network ("FinCen"), U.S. Department of the Treasury similar to the July 22, 2016 Order but revising the Order to capture a broader range of transactions and includes transactions involving fund transfers. This order period is effective beginning September 22, 2017 and ending March 20,2018.
Please note that the reporting forms sent with our initial memorandum dated August 19, 2016 have been updated to now include wire transfers in the definition of Covered Transactions. Links to these two forms are listed below.
All other procedures and requirements as set forth in the previous two memos remain in effect.
As before, NITIC will handle the reporting of all Covered Transactions for agents and subsidiaries. Should you have any questions regarding this order or the attached forms, please immediately contact:
Mike W. Aiken
Senior Vice President
National Investors Title Insurance Company
[email protected]
Direct: 919-945-2549
