Virginia, Maryland, and D.C. title agents have recently been included in the list of areas that require all cash real estate transactions be documented in a specific way. In our previous post, we reported that the Finance Crimes Enforcement Network (FinCEN) expanded Geographic Targeting Orders (GTOs), which target suspicious real estate transactions for potential money laundering.
Check out this article for more details on the counties involved and their rules. Here’s a quick list of the main points you should know from the article:
1. MD: Baltimore City/County, Montgomery, Anne Arundel, Prince George’s, and Howard counties
2. VA: Arlington and Fairfax Counties, Alexandria, Falls Church, and Fairfax
3. All of Washington D.C.
4. Transactions amounting to $300,000 or more ($50,000 in Baltimore City/County) without a bank loan or financing must be reported
5. FinCEN Currency Transaction Report must be filed within 30 days from closing of the Covered Transaction
6. ALTA GTO Information Collection Form helps document the transaction
7. Title agents must educate the real estate agents they work with about what information will be required
8. Ignorance of the law will not absolve title agents from potential fines and penalties
Be sure to review internal procedures for large cash transactions, and refer to your local land title administration for up-to-date practices and tips to prevent any fines or penalties.