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Anti-Money Laundering Beneficial Owner Geographic Targeting Order

Dorsey & Whitney LLP

FinCEN Proposes AML Compliance Obligations for Non-Financed Real Estate Transactions

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Following consideration of comments received from an Advanced Notice of Proposed Rulemaking, on February 16, 2024, FinCEN issued a proposed rule (the “Proposed Rule”) that for the first time would require non-financed...more

Bilzin Sumberg

U.S. Transparency Updates

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The United States has started with a bang for 2024 with respect to transparency initiatives. The initiatives affect real estate, financial and business sectors. This alert provides a brief overview of the developments in...more

Morrison & Foerster LLP

FinCEN Proposes Expanding Residential Real Estate Anti-Money Laundering Rules

On February 16, 2024, the Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking, which would require certain real estate professionals to report certain transaction information to FinCEN in...more

Holland & Knight LLP

FinCEN Proposal for Nonfinanced Purchases of Residential Real Estate and Gratuitous Transfers

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The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on Feb. 7, 2024, issued a Notice of Proposed Rulemaking (NPRM) proposing a new nationwide reporting obligation to be imposed on settlement...more

Troutman Pepper

FinCEN's Proposed New Rule to Increase Reporting Requirements in Residential Real Estate

Troutman Pepper on

On February 7, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed a new rule to increase reporting requirements for nonfinanced, entity-purchased residential real estate. FinCEN...more

Bilzin Sumberg

Unanswered Questions on the Corporate Transparency Act

Bilzin Sumberg on

The National Defense Authorization Act for 2021 enacted on January 1, 2021 contains Title LXI, the Corporate Transparency Act (“Act”). It institutes new reporting requirements for legal entities with few employees and limited...more

Ballard Spahr LLP

FinCEN Renews Real Estate GTOs

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As expected, on May 8, 2020, the Financial Crimes Enforcement Network (“FinCEN”) reissued its Geographic Targeting Orders (“GTOs”) requiring U.S. title insurance companies to identify the natural persons behind legal entities...more

Ballard Spahr LLP

FinCEN Stresses Transparency, BSA Filing Data, and Perils of “Under- Regulating” to Securities Industry

Ballard Spahr LLP on

Last Thursday, FinCEN Deputy Director Jamal El-Hindi appeared at the 20th annual Anti-Money Laundering (AML) and Financial Crimes Conference hosted by the Securities Industry and Financial Markets Association (SIFMA) in New...more

Ballard Spahr LLP

FinCEN Renews GTOs

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On November 8, 2019, the Financial Crimes Enforcement Network (“FinCEN”) reissued its Geographic Targeting Orders (“GTOs”) requiring U.S. title insurance companies to identify the natural persons behind legal entities used in...more

Foodman CPAs & Advisors

Residential Real Property Purchased with Virtual Currency must be Reported

On November 15, 2018, the Financial Crimes Enforcement Network (FinCEN) announced the issuance of a “Revised” Geographic Targeting Order (GTO) that requires U.S. title insurance companies (Covered Business) to identify the...more

Ballard Spahr LLP

More on AML Reform: Artificial Intelligence, Beneficial Ownership and Real Estate

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Second Post in a Two-Part Series - In our first post in this series, we described how the U.S. Senate Committee on Banking, Housing, and Urban Affairs (the “Banking Committee”) met in open session late last week to conduct a...more

Blake, Cassels & Graydon LLP

Confronting Money Laundering and Terrorist Financing: Canada Considers Vast Changes to AML Regime

The Standing Committee on Finance (Committee) recently released its report, Confronting Money Laundering and Terrorist Financing: Moving Canada Forward (Report), where it makes 32 recommendations on proposed modifications and...more

Holland & Knight LLP

West Coast Real Estate Update - September 2018

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Title Insurance Firms Paying Close Attention to Latest Measure Imposing Russian Sanctions - The Defending American Security from Kremlin Aggression Act of 2018, a bipartisan bill introduced in the U.S. Senate last month,...more

Ballard Spahr LLP

FinCEN Renewal of GTOs for High-End Cash Buyers in Six Markets

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FinCEN announced today that it is renewing the existing Geographical Targeting Orders (GTOs) issued in July 2016 that require all title insurance companies to identify and report on the natural persons behind shell companies...more

The Volkov Law Group

FinCEN Expands Crackdown on Real Estate Buyers

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Building on early successes, the Financial Crimes Enforcement Network (“FinCEN”) announced new rules targeting buyers of high-end real estate properties. Earlier this year, FinCEN adopted rules focusing on high-end...more

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