Financial Crimes Enforcement Network (FinCEN) Reporting

On January 13, 2016, Financial Crimes Enforcement Network (FinCEN) issued Geographic Targeting Orders requiring “certain U.S. title insurance companies to identify the natural persons behind companies used to pay ‘all cash’ for high-end residential real estate in the Borough of Manhattan in New York City, New York and Miami-Dade County, Florida.” This information will be…