Informational only. Always verify at FinCEN.gov before making compliance decisions. Last refreshed: 2026-10-14.
“The District of Columbia; Arlington County and Fairfax County, Virginia; Montgomery County and Prince George's County, Maryland”
Threshold
$300,000
Effective
December 1, 2024
Expires
February 28, 2026
Geography
county
This GTO covering the Washington DC metro area (DC, Arlington, Fairfax, Montgomery, and Prince George's counties) was superseded on March 1, 2026 by FinCEN's nationwide residential real estate reporting rule, which replaced all geographic targeting orders with a permanent nationwide program.
Formal Geographic Text (from order)
“The District of Columbia; Arlington County and Fairfax County, Virginia; Montgomery County and Prince George's County, Maryland”
DC metro area covering the District and four surrounding counties. DC FIPS: 11001; Arlington FIPS: 51013; Fairfax FIPS: 51059; Montgomery MD FIPS: 24031; PG County FIPS: 24033.
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 $300,000; file a FinCEN Currency Transaction Report via BSA E-Filing System within 30 days of closing
Threshold
$300,000
All-cash transactions at or above
Source Agency
FinCEN
FinCEN order PDF | FinCEN news release
Renewed at $300K threshold.
Superseded by FinCEN nationwide residential real estate reporting rule effective March 1, 2026.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
Covers multi-state metro area (DC, VA, MD). Superseded by FinCEN's permanent nationwide rule (March 1, 2026).
Soflo Consulting
We offer risk assessments, AML policy creation, and AML program reviews & gap analysis for businesses operating in FinCEN GTO-covered jurisdictions.
