News & Analysis as of

Suspicious Activity Reports (SARs) Real Estate Investments Anti-Money Laundering

Dorsey & Whitney LLP

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

Dorsey & Whitney LLP on

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

ArentFox Schiff

Calling all Cash Money Millionaires: FinCEN Proposes New Reporting Rules for Cash Residential Real Estate Transfers

ArentFox Schiff on

“In residential real estate sales, all parties involved, including sellers, developers, title companies, attorneys, and closing agents, need to be aware of reporting requirements. Consider a situation where a commercial...more

Cadwalader, Wickersham & Taft LLP

FinCEN's Proposed Streamlined SAR -- The Real Estate Report

On February 16, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a proposed rule addressing “Anti-Money Laundering Regulations for Residential Real Estate Transfers.” The proposed rule would, among other...more

Falcon Rappaport & Berkman LLP

FinCEN’s Anti-Money Laundering Regulations for Residential Real Estate Transfers

To crack down on money-laundering in the U.S. residential real estate market, the Financial Crimes Enforcement Network (“FinCEN”) has proposed new reporting requirements for certain real estate transactions. Specifically, the...more

Ballard Spahr LLP

FinCEN Proposes BSA Reporting Requirements for Residential Real Estate

Ballard Spahr LLP on

On February 16, the Financial Crimes Enforcement Center (“FinCEN”) published a Notice of Proposed Rulemaking (“NPRM”) regarding residential real estate. The final version of the NPRM published in the Federal Register is 47...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

Ballard Spahr LLP

FinCEN Renews and Expands GTO

Ballard Spahr LLP on

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

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