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Category: Closings


GEOGRAPHIC TARGETING ORDERS: BACK AND BIGGER THAN EVER

August 12th, 2016 — 11:06am

geotargetThe United States Treasury’s Financial Crimes Enforcement Network (“FinCEN”) will continue to track all-cash purchases of high-end real estate in an effort to combat money laundering. FinCEN’s method? Another Geographic Targeting Order.

As we wrote about previously in this space, in January 2016 FinCEN issued Geographic Targeting Orders covering all-cash deals over certain thresholds in Manhattan ($3,000,000) and Miami ($1,000,000). The first Geographic Targeting Order (“GTO”) was effective from March 1, 2016 through August 27, 2016. The new GTOs pick up right where the first ones left off, on August 28, and they will run through February 23, 2017. Continue reading »

1 comment » | Closings, FinCEN, Geographic Targeting Order, Going Private, GTO's, News

This GTO Is Not a Dream Vehicle: Another Blow to Privacy

July 9th, 2016 — 12:47pm

punchOn January 13, 2016, the United States Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a Geographic Targeting Order, or “GTO”, covering the Borough of Manhattan. The GTO was ostensibly issued in response to the media blitz around the use of shell companies to launder money via the purchase of real property. Continue reading »

Comment » | Closings, FinCEN, Geographic Targeting Order, Going Private, GTO's, News

The HUD Tail That Wags The Dog

January 16th, 2013 — 9:42am

More and more, real estate attorneys are going to closings which are delayed one, two, three or even four hours.  In a typical scenario, the closing is scheduled for 11AM, everyone arrives on time and the closing almost finishes smoothly but…  The buyer’s bank attorney does not have checks and everyone starts getting anxious.  The seller has moved out, the buyer’s movers are on their way and the seller needs to bring those checks to another closing to buy another apartment. Continue reading »

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