Informational tool only. Always verify GTO status directly with FinCEN's official GTO resources page before making compliance decisions. Dataset refreshed weekly. Last update: 2026-10-18.
FinCEN Geographic Targeting Order Map
What is a FinCEN GTO, and is your jurisdiction covered?
Active GTOs
2
States / Jurisdictions
50
Last Refreshed
2026-10-18
Next Refresh
Oct 19, 2026
Residential Real Estate Rule Vacated by Federal Court
Showing 2 of 44 orders
Show Historical GTOs
Expired & superseded orders
Threshold Amount
State
2 Orders
Historical hidden2 Orders
Historical hiddenActive Reporting Requirements
2 active requirements · Click any row to open the full detail page
Hennepin County, Ramsey County
county
Effective
Feb 12, 2026
Expires
Feb 10, 2027
Cameron County, TX, El Paso County, TX +6
ZIP code
Effective
Sep 3, 2026
Expires
Mar 1, 2027
State | Jurisdiction | Industry | Threshold | Effective | Expires | Source |
|---|---|---|---|---|---|---|
| MN | Hennepin County, Ramsey County county | banking | $3K | Feb 12, 2026 | Feb 10, 2027 | FinCEN PDF |
| TX | Cameron County, TX, El Paso County, TX +6 ZIP code | money services businesses | $1K | Sep 3, 2026 | Mar 1, 2027 | FinCEN PDF |
2 active requirements · Data version sync-2026-10-18
Verify at FinCEN.gov →What Is a FinCEN GTO?
A Geographic Targeting Order (GTO) is a legal tool used by the U.S. Treasury's Financial Crimes Enforcement Network (FinCEN) to require specific businesses in specific locations to collect and report information about certain transactions.
Think of it as a temporary, location-specific compliance requirement layered on top of standard Bank Secrecy Act (BSA) obligations. If your business is in a covered area and handles covered transactions, you must comply, even if you've never had to before.
The most common GTOs target real estate transactions - specifically, all-cash purchases of residential property by legal entities (LLCs, corporations, trusts, etc.) above a dollar threshold. Title insurance companies are the primary reporting entities.
Duration
Typically 180 days; renewed repeatedly since 2016
Geographic Scope
County or metro-area level, not statewide or national
Who Reports
Title insurance companies (real estate GTOs); MSBs (MSB GTOs)
What Triggers It
All-cash purchase by a legal entity at or above the threshold
How to Report
FinCEN Currency Transaction Report (via BSA E-Filing)
Frequently Asked Questions
A GTO is a temporary order issued by the Financial Crimes Enforcement Network (FinCEN) under the Bank Secrecy Act. It requires certain businesses in specific geographic areas to collect and report information about certain transactions, typically all-cash purchases above a dollar threshold. GTOs are used to gather intelligence on money laundering and other financial crimes.
Real estate GTOs primarily target title insurance companies. If your company issues title insurance for residential real property transactions in a covered jurisdiction, you must collect beneficial ownership information for legal entities (LLCs, corporations, partnerships, trusts) that purchase property for all-cash at or above the threshold amount.
Covered businesses must collect and report: (1) the identity of the legal entity purchasing the property, (2) the identity of the beneficial owner(s) of that entity, meaning the natural persons who own or control it, and (3) details of the transaction including purchase price, property address, and payment method. Reports are filed using a FinCEN Currency Transaction Report.
When a GTO expires, the enhanced reporting requirements end unless FinCEN issues a renewal. Real estate example: FinCEN renewed the residential real estate GTO program repeatedly from 2016 until the final order (Phase 20) expired on February 28, 2026, ending that program. Money services business example: the Southwest Border MSB GTO has been renewed repeatedly, most recently by the order effective September 3, 2026 through March 1, 2027. When an order is not renewed, businesses revert to their standard BSA/AML obligations. Always check FinCEN's official GTO page for current status before making compliance decisions.
No. GTOs are temporary, targeted orders. FinCEN has separately finalized a permanent rule (31 C.F.R. Part 1031) requiring beneficial ownership reporting for all non-financed residential real estate transfers nationwide, effective March 1, 2026. However, on March 19, 2026, the U.S. District Court for the Eastern District of Texas vacated the rule in Flowers Title Companies v. Bessent. Reporting persons are not currently required to file real estate reports with FinCEN and are not subject to liability if they fail to do so. All prior residential real estate GTOs remain superseded.
The threshold is the minimum transaction value that triggers reporting. Under the GTO program, most nationwide phases (17-20) used a $300,000 threshold. The permanent rule (31 C.F.R. Part 1031) does not set a fixed dollar threshold - it applies to all covered non-financed transfers. Only all-cash purchases by legal entities (not natural persons buying in their own name) are covered under both frameworks.
SAR filing was not required under any GTO. Title and settlement companies are not subject to a SAR filing requirement. You may file a voluntary SAR through FinCEN's BSA E-Filing System if you wish. The permanent rule (31 C.F.R. Part 1031) was vacated March 19, 2026 (Flowers Title Companies v. Bessent, E.D. Tex.). Reporting persons are not currently required to file real estate reports with FinCEN.
What the GTO required vs. what the rules require
GTO Framework
- Beneficial ownership ID
- Currency Transaction Report filing
- Recordkeeping (5 yrs)
- No SAR filing required
- No written AML program
RRE Reporting Rule
31 C.F.R. Part 1031 · Vacated March 19, 2026
- Beneficial ownership ID
- Form 8300 (still applies)
- Recordkeeping (5 yrs)
- SAR filing - voluntary
Vacated March 19, 2026 (E.D. Tex.)
Proposed AML Program Rule
No pending proposed rule for real estate professionals as of this writing
- Written AML/CFT program
- Designated compliance officer
- Ongoing employee training
- Independent testing/audit
Proposed rule - not yet in effect
When should you consider filing a SAR?
Title and settlement companies are not subject to a SAR filing requirement. You may file a voluntary SAR through FinCEN's BSA E-Filing System when you know, suspect, or have reason to suspect a transaction:
- Involves funds derived from illegal activity or is intended to evade BSA reporting
- Has no lawful purpose or is not the type of transaction the customer would normally conduct
- Involves use of your firm to facilitate criminal activity
- Relates to a customer who refuses to provide required beneficial ownership information
Reference Only
30 days / 60-day extension
Deadline that applies to institutions with a mandatory SAR rule - not to title/settlement companies under Part 1031
Tipping-Off Prohibition
You may not disclose to the subject of a SAR - or to anyone outside your firm and regulators - that a SAR has been filed or is under consideration. Violation of the tipping-off prohibition is a federal crime under 31 U.S.C. § 5318(g)(2).
Bottom line: If your compliance program was built solely around the GTO checklist - identity collection and Currency Transaction Report filing - it would not satisfy the permanent rule. However, the rule was vacated on March 19, 2026 by the U.S. District Court for the Eastern District of Texas (Flowers Title Companies v. Bessent). Reporting persons are not required to file real estate reports with FinCEN. A separate proposed AML program rule (written program, compliance officer, training, audit) has not been finalized. Monitor FinCEN.gov/rre for updates on both rules.
Need Help Building a GTO-Compliant AML Program?
We offer risk assessments, policy creation, and AML program reviews & gap analysis tailored to businesses operating in FinCEN GTO-covered jurisdictions. Whether you're a title company, real estate firm, or MSB operator, we help you stay compliant.
GTO Compliance Assessment
Determine if your business is covered and what obligations apply to your specific transactions and jurisdiction.
AML Policy Creation
Draft or update your AML/BSA policies and procedures to incorporate GTO-specific reporting requirements.
AML Program Review & Gap Analysis
Professional review of your existing AML program to identify gaps, weaknesses, and GTO compliance deficiencies.
Staff Training
Customized training for your compliance team, operations staff, and management on GTO obligations and red flags.
31 C.F.R. Part 1031 Compliance for Title Companies & Settlement Agents
The permanent rule was set to replace all GTOs on March 1, 2026, but was vacated March 19, 2026 (Flowers Title Companies v. Bessent). Get the full comparison table, action checklist, and voluntary SAR analysis guide - all on one page.
FinCEN's Residential Real Estate Rule Was Vacated. Here's What Title Companies Should Do Now.
The three paths the rule could return (appeal, emergency stay, new rulemaking), and why the correct posture is prepare, not panic.
FinCEN Renews Minnesota GTO to Combat Fraud Schemes Draining Billions in State and Federal Funds
Why the Minnesota GTO is different from real estate GTOs, the staggering scale of government benefits fraud in Minnesota, and what covered financial institutions and MSBs need to do to stay compliant.
Voluntary SAR Analysis Tool for Title Companies
8-question analysis framework to determine whether a transaction warrants voluntary SAR consideration. Title and settlement companies have no SAR filing requirement (FinCEN FAQ L.4/L.5). Includes 25+ real estate red flags.
Want to see the full compliance platform?
Explore the live training portal, manager dashboard, and certificates, with no login needed.
What To Do After March 1, 2026
No federal rule currently requires title or settlement companies to maintain an AML program. 31 C.F.R. Part 1031 required reports only (31 CFR 1031.320) and was vacated March 19, 2026 (Flowers Title Companies v. Bessent, E.D. Tex.). The items below are voluntary best practices, not legal requirements. Title and settlement companies have no SAR filing requirement (FinCEN FAQ L.4/L.5). Check items off as you complete them - your progress is tracked below.
Work through each category below
Consider drafting a written AML policy & procedures outline (voluntary)
Consider designating someone to oversee voluntary AML practices
Consider a periodic internal review of your voluntary practices
Consider ongoing staff awareness training
Voluntary SAR Registration
Title and settlement companies have no SAR filing requirement (FAQ L.4/L.5). If you choose to file, register on FinCEN's BSA E-Filing System in advance - you cannot file without an active account.
Read the Final Rule
Review the full text of 31 C.F.R. Part 1031 at FinCEN's official resource page for the most current requirements.
Need Expert Help?
Soflo Consulting can build or review your AML program, draft policies, and prepare you for a regulatory examination.
Voluntary SAR Analysis Tool for Title Companies
Interactive tool8-question analysis framework to determine whether a transaction warrants voluntary SAR consideration. Title and settlement companies have no SAR filing requirement (FinCEN FAQ L.4/L.5). Includes 25+ real estate red flags.
31 C.F.R. Part 1031 Compliance Guide for Title Companies & Settlement Agents
Dedicated resourceFull GTO vs. Part 1031 comparison table, interactive compliance checklist, and voluntary SAR analysis FAQ - everything on one focused page targeted at the permanent rule.
Reference This GTO Map
This FinCEN Geographic Targeting Order Map is publicly available as an educational resource. Compliance teams, title professionals, attorneys, financial institutions, journalists, and researchers are welcome to reference or link to it.
No permission is required to link to a public webpage. You may cite the map in articles, memos, training material, or internal guidance without asking for approval first. A link back is always appreciated, never required.
Soflo Consulting, "FinCEN Geographic Targeting Order Map," https://sofloconsulting.net/gto-map (accessed October 22, 2026).
Where the Data Comes From
Last reviewed
2026-10-18
Dataset version sync-2026-10-18 · refreshed weekly every Monday
Primary official source
FinCEN Geographic Targeting Orders
Every record links to the underlying FinCEN order, news release, or Federal Register notice
Educational convenience tool
Not legal advice
The map summarizes and organizes public regulatory information for convenience only
Always verify
Confirm with FinCEN before deciding
Regulatory requirements change; check the current official order before making compliance decisions