FinCEN has extended the Geographic Targeting Order (GTO) which expired on August 22, 2017. The extended GTO is effective September 22, 2017 and expires March 20, 2018.
The definition of a Covered Transaction remains the same except that, pursuant to Section II(A)(2)(iv) of the GTO a purchase made, at least in part, using currency or a cashier’s check, a certified check, a traveler’s check, a personal check, a business check, a money order in any form or a funds transfer must be reported. Previously, transactions completed using a wire transfer were exempt from the reporting requirement. Purchases made using a wire transfer must now be reported.
For transactions closing between August 23, 2017 and September 21, 2017, the GTO will not apply. FinCEN will accept voluntary filings during that period.