News & Analysis as of

Real Estate Market Money Laundering

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

Real Estate and Money Laundering: FinCEN Issues Advanced Notice of Regulations for the Real Estate Industry

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On December 6, FinCEN announced that it was issuing an Advanced Notice of Proposed Rulemaking (“AMPRM”) to solicit public comment on potential requirements under the Bank Secrecy Act (“BSA”) for certain persons involved in...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

Treasury Report Targets Money Laundering Risks in Real Estate and Gatekeeper Professions

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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

Ballard Spahr LLP

FinCEN Renews Real Estate GTOs: Expanded Geographic Coverage and Reduced Monetary Thresholds

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The Financial Crimes Enforcement Network (“FINCEN”) announced on November 15 that it has renewed and revised its Geographic Targeting Orders (“GTOs”) that require U.S. title insurance companies to identify the natural persons...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

Foodman CPAs & Advisors

Did you know that GTO’s have a $300,000 Threshold?

A GTO is a Geographic Targeting Order issued by the Financial Crimes Enforcement Network (FinCEN) under the Bank secrecy Act (BSA) for a specific geographic area. ...more

Fox Rothschild LLP

FinCEN Quietly Extends Real Estate Geographic Targeting Orders For Another Six Months

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Breaking from its recent practice of making public announcements about Geographic Targeting Orders, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) last month quietly extended its real estate GTOs for...more

Ballard Spahr LLP

Alleged Nigerian Oil Industry Corruption and Civil Forfeiture: More Extraterritorial Application of U.S. Law; More High-End Real...

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On Friday, the Department of Justice (“DOJ”) filed a civil forfeiture complaint in the Southern District of Texas seeking recovery of approximately $144 million in assets that allegedly represent the proceeds of foreign...more

Hogan Lovells

Money Laundering Regulations 2017: government rush threatens a teething period for property auctioneers

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New money laundering regulations could prove to be a headache for property auctioneers until those affected get to grips with the changes, according to leading figures in the industry....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

Ballard Spahr LLP

2016 Year in Review: Money Laundering (Part One)

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2016 was a busy year for developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues. In part one of our year-in-review, we discuss six key...more

Ballard Spahr LLP

China's Stringent New Rules on Yuan Transfers Could Hinder EB-5 Fundraising

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The Chinese government has enacted new rules severely limiting foreign currency transfers out of China. The scope of the limitations are not clear but the Xinhua News Agency reported that Chinese banks advised their customers...more

Ballard Spahr LLP

FinCEN Expands Targeting of High-End Cash Real Estate Transactions

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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

Cadwalader, Wickersham & Taft LLP

FinCEN Tightens the Screws on Money Launderers with Additional Scrutiny of High-Value Residential Real Estate Transactions

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

Holland & Knight LLP

West Coast Real Estate Update: June 2016 #1

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California Governor Proposes "Build By Right" Approval Process for Affordable Housing - Recognizing the extreme need throughout California for construction of new affordable housing units, on May 13, 2016, Gov. Jerry...more

Sheppard Mullin Richter & Hampton LLP

Are You Within Reach of Anti-Money Laundering Enforcement? The Tentacles of Money Laundering Schemes Affect Real Estate Investors...

The U.S. Treasury Department has signaled the latest focus of its enforcement: real estate ventures with ties to money laundering schemes. Individual real estate investors and companies involved in luxury real estate, real...more

Ballard Spahr LLP

FinCEN Director Discusses Initiatives to Address Money Laundering Through Real Estate

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The Financial Crimes Enforcement Network's (FinCEN) continuing efforts to address the "real estate industry's vulnerability to money laundering” were outlined by FinCEN Director Jennifer Shasky Calvery in an April 12, 2016,...more

Holland & Knight LLP

West Coast Real Estate Update: Feb. 2016 #3

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Los Angeles Ballot Proposal To Halt Developer's Zoning Changes - A group called "Coalition to Preserve L.A." is proposing a ballot measure that would impose a two-year moratorium on all projects in the city of Los...more

Locke Lord LLP

U.S. Treasury Department to Scrutinize Certain All Cash Real Estate Transactions in New York City and Miami-Dade County

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On January 13, 2016, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued two temporary Geographic Targeting Orders (the Orders) that will require title insurance companies to identify...more

Cooley LLP

Blog: A Proposal To Extend Beneficial Ownership Rules To UK Land-Holding Foreign Companies

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A report published yesterday by Global Witness, alleging that an individual with ties to a former Kazakh public official owns large swathes of London, follows much recent interest in the issue of public officials owning...more

Snell & Wilmer

Global Connection - June 2015

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The latest edition of Global Connection offers insight into a potential money laundering crackdown in the real estate sector, information on the Federal Trade Commission’s approach to data breach investigations and a legal...more

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