Informational only. Always verify at FinCEN.gov before making compliance decisions. Last refreshed: 2026-10-14.

Aerial view of an American city skyline at dusk with financial district buildings
Superseded
real estate
title insurance
Renewal #1

Geographic Targeting Order - Northern Virginia Independent Cities (Real Estate) 2024

“The City of Alexandria, the City of Falls Church, and the City of Fairfax, Virginia”

Threshold

$300,000

Effective

December 1, 2024

Expires

February 28, 2026

Geography

city

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Order Summary

This GTO covered three independent cities in Northern Virginia - Alexandria, Falls Church, and Fairfax City - which are legally separate from the surrounding counties. Together with Arlington County and Fairfax County (tracked separately), these jurisdictions formed the complete Northern Virginia GTO coverage area. The GTO was superseded on March 1, 2026 by FinCEN's nationwide residential real estate reporting rule.

Geographic Coverage

3 areas shown
Leaflet © OpenStreetMap contributors © CARTO
City of Alexandria
City of Falls Church
City of Fairfax

Formal Geographic Text (from order)

“The City of Alexandria, the City of Falls Church, and the City of Fairfax, Virginia”

Three independent cities in Northern Virginia (separate from Fairfax County and Arlington County, which are tracked in gto-re-dc-nova-2024-01). Alexandria FIPS: 51510; Falls Church FIPS: 51610; Fairfax City FIPS: 51600.

Reporting Requirements

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

Change Log

IssuedApril 29, 2022

Northern Virginia independent cities added to GTO program.

RenewedNovember 15, 2024

Renewed at $300K threshold.

ExpiredMarch 1, 2026

Superseded by FinCEN nationwide residential real estate reporting rule effective March 1, 2026.

Frequently Asked Questions

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

Virginia has independent cities that are legally separate from counties - these must be listed separately. Arlington County and Fairfax County are in gto-re-dc-nova-2024-01. Superseded by FinCEN's permanent nationwide rule (March 1, 2026)

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