On April 17, FinCEN renewed its Geographic Targeting Orders (GTOs) which require title insurance companies to identify the real owners of shell companies involved in cash real estate purchases. This renewal is effective from...more
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
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
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
While many Americans are struggling to achieve the dream of homeownership, there are criminals that abuse the housing market for financial gain. To avoid the scrutiny of financial institutions that have anti-money laundering...more
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
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
FinCEN announced on October 20 that, once again, it is extending the Geographic Targeting Order, or GTO, which requires U.S. title insurance companies to identify the natural persons behind so-called “shell companies” used in...more
As I discussed in Identifying Suspicious Activity in Real Estate Transactions, the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) has long had its eye on the real estate industry. As with Hatto’s...more
In This Issue. The Board of Governors of the Federal Reserve System (Federal Reserve), in response to an increased number of inquiries and access requests from companies with fintech and other narrow purpose charters, invited...more
Meanwhile, Congress Wants a Report on Russian Money Laundering and Its Relationship to the Real Estate Industry FinCEN announced today that, once again, it is extending the Geographic Targeting Order, or GTO, regarding...more
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
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
In its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”), the U.S. Department of Treasury (“Treasury”) has laid out its AML and money laundering enforcement priorities. Last week, we...more
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
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
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
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
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
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
Regulators and enforcement agencies continue to pursue aggressive regulations and requirements for financial institutions (a very broad definition under Title 31 of the US Code and regulations). The new administration does...more
This article is Part II of a series in which we address the U.S. government’s attempts to combat money laundering in real estate transactions....more
The Financial Crimes Enforcement Network (FinCEN) announced on August 22, 2017, that it is expanding its earlier Geographic Targeting Orders (GTO) that require U.S. title insurance companies to identify the natural persons...more
Yesterday the Financial Crimes Enforcement Network (FinCEN) announced the issuance of revised Geographic Targeting Orders (GTOs) that require U.S. title insurance companies to identify the natural persons behind shell...more
In a press release touting recent law enforcement success stories based upon Bank Secrecy Act reporting by financial institutions, the Treasury Department’s Financial Crimes Enforcement Network revealed publicly for the first...more