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On August 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) finalized a rule to require reporting of certain US residential real estate transactions (“Final Rule”). The Final Rule...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
El 7 de febrero de 2024, FinCEN emitió un Aviso de Reglamentación Propuesta (NPRM) para combatir y disuadir el lavado de dinero en el sector inmobiliario residencial de EE. UU. mediante el aumento de la transparencia. FinCEN...more
On February 07, 2024, FinCEN issued a Notice of Proposed Rulemaking (NPRM) to combat and deter money laundering in the U.S. residential real estate sector by increasing transparency. FinCEN is seeking to require certain...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
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
On April 21, FinCEN updated its Geographic Targeting Orders (GTOs). The GTOs require U.S. title insurance companies to identify the natural persons behind shell companies that pay “all cash” (i.e., the transaction does not...more
Second of Two Posts on Evolving Issues Regarding Real Estate and Money Laundering - In our last post, we blogged on a major regulatory tool to combat the use of real estate as a potential vehicle for money laundering: the...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
The Financial Crimes Enforcement Network (“FinCEN”) has, once again, extended its Geographic Targeting Order (“GTO”) 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
“Sanctions Bill from Hell” Targets Real Estate Deals - On February 13, 2019, Sen. Lindsay Graham (R – S.C.) introduced S.482 – the Defending American Security from Kremlin Aggression Act of 2019 (“DASKAA”), a bill intended...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
We previously reported that the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) had quietly extended its Geographic Targeting Orders directed at the luxury residential real estate market for another six...more
As the world now knows, an indictment against Paul Manafort, Jr., a former campaign chairperson for now-President Donald Trump, and Manafort’s associate, Richard Gates III, was unsealed yesterday. ...more
On August 22, 2017, FinCEN (Financial Crimes Enforcement Network) published a new Advisory regarding Geographic Targeting Orders (GTOs) covering residential real estate transactions in certain counties or boroughs of New...more
In its latest effort to combat money laundering within the real estate sector, the Financial Crimes Enforcement Network (“FinCEN”) has issued a new Geographic Targeting Order (“GTO”) broadening its scrutiny of shell companies...more
• The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) continues to expand its Geographic Targeting Orders (GTOs) with respect to beneficial ownership transparency in real estate transactions. ...more
Gov. Brown Opposes Measure S - In a statement published less than two weeks before Los Angeles' Consolidated Municipal and Special Elections to be held on March 7, 2017, California Gov. Jerry Brown came out in opposition...more
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
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
FinCEN has announced a major expansion and extension of its geographic targeting orders (GTOs) aimed at high-end cash buyers of real estate. This action reflects FinCEN’s continued efforts to prevent money laundering through...more
Choice real estate markets such as New York, Miami, Los Angeles, San Francisco, San Diego, and San Antonio may offer enticing amenities like buzzing nightlife or sunny beaches, but thanks to the Financial Crimes Enforcement...more