Thinking about paying cash through an LLC or Land Trust to hide the transaction? Think again.
On January 13, 2016, the Director of the Financial Crimes Enforcement Network (“FinCEN”), U.S. Department of the Treasury, issued her Geographic Targeting Orders (“Order”) requiring title companies to collect and report financial information about the persons involved in certain residential real estate transactions. The purpose of this Order is to begin governmental inquiry into the persons behind the legal entities which buy residential real estate using cash. The government is concerned that these cash transactions are a means by which drug smugglers are moving cash into the US.
The GTO requires title companies to report information about the identity of the individual primarily responsible for representing the purchaser in transactions involving $1 million for residential real estate located in Miami-Dade County and $3 million for residential real estate located in Manhattan, NY. The GTO covers transactions at using, least in part, currency or cashier’s check, a certified check, traveler’s check, or money order in any form. The effective date of this Order is March 1, 2016 and continues through August 27, 2016.
If you have any questions concerning this Order please give me a call. I am happy to answer any questions.