8/2016 UPDATE: Department of Treasury Expands FinCEN Targeting Order

Wednesday, January 13, 2016 by Chaim Zlotowitz, Esq.



The Department of Treasury has expanded the FinCEN Targeting Order to cover all five Boroughs of New York City, as well as various counties in Florida, Texas, and California. 

In recent years, the upscale Condo market both in NYC and Miami has exploded. It is not uncommon to see single residential condo units being listed for sale -and sold - at prices that eclipse the  cost of a 13 building 600+ unit Bronx portfolio.

Most of these multi-million dollar unit purchasers hold title in LLC's or other opaque entities effectively masking the individual beneficial owner.

But who are the beneficial owners of these "palaces of the sky," you may ask. Are they high net worth individuals that want a modicum of privacy or unscrupulous people who are scheming to use the condo as vehicle to launder money?

That's what the Department of Treasury wants to know. 

 Starting in March, the Federal Government will require certain Title companies to disclose information regarding the natural person behind the LLC or other entity in select transactions in NYC and Miami.

To see the initial press release, follow the below link:


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Riverside is currently one of the top 10 title agencies in New York as well as in New Jersey. In addition, we are ranked nationally as a top 25 agent for Old Republic. Riverside is licensed in over 35 states and facilitate closings in all 50 States including many multi-site commercial deals and a considerable volume of high-end residential transactions. We currently have over $100mm in escrow between our title company and our 1031 exchange division and work in various capacities with many of the most prestigious investors, owners, lenders and law firms.

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