The Financial Crimes Enforcement Network (FinCEN), one of the U.S. Treasury’s leading agencies in the fight against money laundering and financing of terrorism, has renewed the Geographic Targeting Order (GTO) that imposes data collection and reporting requirements on title companies involved in certain high-end real estate transactions.

FinCEN issued an updated GTO effective beginning on April 14, 2025, through September 9, 2025, requiring requires all money services businesses across multiple jurisdictions within California and Texas to file Currency Transaction Reports (CTRs) with FinCEN for transactions of $200 or more. 

The terms of the GTO are effective beginning 30 days after the date on which the order is published in the Federal Register. The terms are effective for 179 days thereafter.

The order covers the following ZIP codes across seven counties in California and Texas:

  • Imperial County, California: 92231, 92249, 92281, 92283
  • San Diego County, California: 91910, 92101, 92113, 92117, 92126, 92154, 92173
  • Cameron County, Texas: 78520, 78521
  • El Paso County, Texas: 79901, 79902, 79903, 79905, 79907, 79935
  • Hidalgo County, Texas: 78503, 78557, 78572, 78577, 78596
  • Maverick County, Texas: 78852
  • Webb County, Texas: 78040, 78041, 78043, 78045, 78046

In accordance with the GTOs, title companies, and their agents, must file a report with FinCEN regarding covered purchases of residential real property meeting the requirements above when such purchases are made without a bank loan or similar external financing and is paid at least in part by using currency or a cashier’s check, a certified check, a traveler’s check, a personal check, a business check, money order, or virtual currency. Pursuant to federal legislation that directed Treasury to allow investigators to obtain additional records to better target illicit Russian activity, the GTOs also now include wire funds transfers.

The GTOs do not impose any new obligations on real estate professionals. However, it is important for members to be aware of these and the potential impact on real estate sales transactions. In the event a transaction is covered by a GTO, the title company may consult with the real estate professional to obtain information necessary to report in compliance with the order. Such communications should not affect the real estate sales transaction or timeline for closing as title companies are required to report GTO covered transactions to FinCEN within 30 days of the closing.

FinCEN also issued updated Frequently Asked Questionspdf regarding the GTOs.