Informational only. Always verify at FinCEN.gov before making compliance decisions. Last refreshed: 2026-10-18.
“San Francisco County, San Mateo County, and Santa Clara County, California”
Threshold
$2,000,000
Effective
August 22, 2017
Expires
March 20, 2018
Geography
county
FinCEN added the San Francisco Bay Area (San Francisco, San Mateo, and Santa Clara counties) to the real estate GTO program in August 2017 with a $2 million threshold. This was part of the major 2017 expansion to seven metropolitan areas and was the first GTO to include wire transfers as a covered payment method alongside cash.
Formal Geographic Text (from order)
“San Francisco County, San Mateo County, and Santa Clara County, California”
Three core Bay Area counties. SF FIPS: 06075; San Mateo FIPS: 06081; Santa Clara FIPS: 06085. Alameda and Contra Costa added in later renewals.
Who Must Report
Title insurance companies
What Must Be Reported
Beneficial ownership of legal entities making all-cash (including wire transfer) residential real estate purchases at or above $2,000,000; file FinCEN Form 8300 within 30 days of closing
Threshold
$2,000,000
All-cash transactions at or above
Source Agency
FinCEN
FinCEN news release
First GTO for SF Bay Area (SF, San Mateo, Santa Clara) with $2M threshold. Wire transfers included for first time.
Superseded by 2018 national renewal.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 August 2017 expansion to 7 metro areas. First GTO to include wire transfers. Alameda and Contra Costa counties added in later renewals (tracked in gto-re-sf-bay-2024-01).
Geographic Targeting Order - Los Angeles County, California (Real Estate)
$2.0M threshold
Geographic Targeting Order - Los Angeles County, California (Real Estate) 2024
$300K threshold
Geographic Targeting Order - San Diego County, California (Real Estate) 2024
$300K threshold
Geographic Targeting Order - San Francisco Bay Area, California (Real Estate) 2024
$300K threshold
Soflo Consulting
We offer risk assessments, AML policy creation, and AML program reviews & gap analysis for businesses operating in FinCEN GTO-covered jurisdictions.
