Informational only. Always verify at FinCEN.gov before making compliance decisions. Last refreshed: 2026-10-14.
“The Borough of Manhattan, New York County, New York”
Threshold
$3,000,000
Effective
March 1, 2016
Expires
August 27, 2016
Geography
county
FinCEN's inaugural Manhattan real estate GTO required title insurance companies to identify beneficial owners of legal entities purchasing residential real property for $3 million or more in all-cash transactions. The higher threshold reflected Manhattan's elevated real estate market compared to Miami.
Formal Geographic Text (from order)
“The Borough of Manhattan, New York County, New York”
Manhattan island (New York County). FIPS: 36061. All residential real property within Manhattan borough boundaries.
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
Original GTO issued for Manhattan with $3M threshold.
Superseded by expanded national GTO program.
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
Issued simultaneously with the Miami-Dade GTO as a paired pilot program.
Soflo Consulting
We offer risk assessments, AML policy creation, and AML program reviews & gap analysis for businesses operating in FinCEN GTO-covered jurisdictions.
