Informational only. Always verify at FinCEN.gov before making compliance decisions. Last refreshed: 2026-10-14.
“Honolulu County, Hawaii”
Threshold
$3,000,000
Effective
August 22, 2017
Expires
March 20, 2018
Geography
county
FinCEN added Honolulu County to the real estate GTO program in 2017 with a $3 million threshold, reflecting the high-value luxury real estate market in Hawaii and concerns about foreign investment in all-cash transactions.
Formal Geographic Text (from order)
“Honolulu County, Hawaii”
Honolulu County (coextensive with the island of Oahu). FIPS: 15003.
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 $3,000,000; file FinCEN Form 8300 within 30 days of closing
Threshold
$3,000,000
All-cash transactions at or above
Source Agency
FinCEN
FinCEN news release
First GTO for Honolulu County with $3M threshold.
Superseded by 2018 national renewal.
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
Part of the 2017 national expansion.
Soflo Consulting
We offer risk assessments, AML policy creation, and AML program reviews & gap analysis for businesses operating in FinCEN GTO-covered jurisdictions.
