By: Scott Cummins, Advisory Director
It is no surprise, efforts to peel back the layers of entities to identify the ultimate owners are critical in the effort to intercept and stop money laundering and illicit activity. FinCEN, through a Geographic Targeting Order (GTO), looked to create a database of beneficial owners purchasing real property, designating specific areas across the country for specific property types and purchase price minimums.
The order, however, was only temporarily instituted. First issued in 2016, GTOs have been renewed every six months, the maximum time limit FinCEN could impose. In January 2021, Congress enacted the Corporate Transparency Act (CTA) looking to create a broader and more permanent reporting requirement.
