Treasury Expands Targeting Orders for Luxury Real Estate Transactions
By: Eli S. Noff, Esq., CPA, Partner and Mary F. Lundstedt, Esq., Associate On January 13, 2016, exercising its authority under the Bank Secrecy Act, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued Geographic Targeting Orders (GTOs), creating an anti-money-laundering data program which requires title