New $300,000 disclosure statute for LLCs would identify every cash buyer at 550 Vanderbilt going forward

An 11/15/18 article in the Real Deal, Treasury dramatically sharpens LLC disclosure rules, tells us that there will be a lot more sunlight on all-cash real-estate deals pursued via limited liability companies, or LLC, aiming to identify those involved in money laundering or other illicit pursuits:

The Treasury Department drastically increased the number of all-cash deals that are subject to its anti-money laundering rules on Thursday.
Starting Nov. 17, title insurance firms will be required to disclose the identity of LLC buyers who spend $300,000 or more on the real estate purchase.
Previously, the rule applied to cash deals above $3 million in Manhattan and $1.5 million in New York City’s other boroughs. 

A good chunk of the condos at 550 Vanderbilt, in Atlantic Yards/Pacific Park, have been bought through LLCs, but many of those deals were under $1.5 million and, based on limited evidence, seem to have involved buyers from China.

The $300,000 threshold would've required every apartment in the 278-unit tower to be subject to disclosure. At least two-thirds of the units are already sold.

The official rules

A press release 11/15/18 from the Treasury Department's Financial Crimes Enforcement Network (FinCEN), FinCEN Reissues Real Estate Geographic Targeting Orders and Expands Coverage to 12 Metropolitan Areas:

WASHINGTON—The Financial Crimes Enforcement Network (FinCEN) today announced the issuance of revised Geographic Targeting Orders (GTOs) that require U.S. title insurance companies to identify the natural persons behind shell companies used in all-cash purchases of residential real estate. The purchase amount threshold, which previously varied by city, is now set at $300,000 for each covered metropolitan area. 

FinCEN is also requiring that covered purchases using virtual currencies be reported.
Previous GTOs provided valuable data on the purchase of residential real estate by persons implicated, or allegedly involved, in various illicit enterprises including foreign corruption, organized crime, fraud, narcotics trafficking, and other violations. Reissuing the GTOs will further assist in tracking illicit funds and other criminal or illicit activity, as well as inform FinCEN’s future regulatory efforts in this sector. 

Today’s GTOs cover certain counties within the following major U.S. metropolitan areas: Boston; Chicago; Dallas-Fort Worth; Honolulu; Las Vegas; Los Angeles; Miami; New York City; San Antonio; San Diego; San Francisco; and Seattle.