Informational only. Always verify at FinCEN.gov before making compliance decisions. Last refreshed: 2026-10-14.
“Baltimore City, Baltimore County, Anne Arundel County, and Howard County, Maryland”
Threshold
$50,000
Effective
December 1, 2024
Expires
February 28, 2026
Geography
county
This GTO covered Baltimore City and three surrounding Maryland counties with a uniquely low $50,000 reporting threshold - the lowest of any GTO jurisdiction, reflecting elevated money laundering risk in the Baltimore market. The GTO was superseded on March 1, 2026 by FinCEN's nationwide residential real estate reporting rule.
Formal Geographic Text (from order)
“Baltimore City, Baltimore County, Anne Arundel County, and Howard County, Maryland”
Baltimore City (independent city, FIPS: 24510) and three surrounding counties: Baltimore County FIPS: 24005; Anne Arundel County FIPS: 24003; Howard County FIPS: 24027. Note: Baltimore has a uniquely low $50,000 threshold vs. the standard $300,000.
Who Must Report
Title insurance companies
What Must Be Reported
Beneficial ownership of legal entities making all-cash residential real estate purchases at or above $50,000 (Baltimore City and County) or $300,000 (Anne Arundel and Howard counties); file a FinCEN Currency Transaction Report via BSA E-Filing System within 30 days of closing
Threshold
$50,000
All-cash transactions at or above
Source Agency
FinCEN
FinCEN order PDF | FinCEN news release
Baltimore City and County added to GTO program with $50,000 threshold - lowest of any GTO jurisdiction.
Renewed. Baltimore threshold remains $50,000.
Superseded by FinCEN nationwide residential real estate reporting rule effective March 1, 2026.
Common questions about this specific GTO, with answers grounded in the official order text.
These answers are for informational purposes only and are grounded in the official FinCEN order text. They do not constitute legal advice.
Analyst Notes
Baltimore has the lowest GTO threshold of any jurisdiction ($50,000 vs. standard $300,000). This reflects FinCEN's assessment of elevated money laundering risk in the Baltimore real estate market. Superseded by FinCEN's permanent nationwide rule (March 1, 2026).
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