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FinCEN › Beneficial Owner › Geographic Targeting Order

The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of... more +
The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of money laundering, terrorist financing and other financial crimes by collecting, monitoring, and analyzing financial transaction data. Such data is disseminated to both domestic and international law enforcement agencies. less -
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

Foodman CPAs & Advisors

Reporte Real Estate De FinCEN

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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

Foodman CPAs & Advisors

Real Estate Report From FinCEN

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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

Morrison & Foerster LLP

FinCEN Proposes Expanding Residential Real Estate Anti-Money Laundering Rules

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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

Sherman & Howard L.L.C.

Financial Crimes Enforcement Network: U.S. Treasury is Monitoring Cash Residential Purchases

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Starting on April 25, 2023, and ending on October 21, 2023, the U.S. Department of the Treasury Financial Crimes Enforcement Network (FinCEN) is requiring disclosure of beneficial ownership of entities that purchase...more

Ballard Spahr LLP

Investigative Journalists Lose FOIA Bid to Obtain GTO Info Reported to FinCEN

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Case Highlights Confidentiality of BSA Reporting and Continued Focus on Real Estate as Money Laundering Tool - The Northern District of California granted summary judgment to the Financial Crimes Enforcement Network...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

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

Civil Forfeiture of Real Estate to Fight Money Laundering: A Round-Up

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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

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

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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

Ballard Spahr LLP on

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

Ballard Spahr LLP

FinCEN’s Evolving Approach to Lurking Threats in Money Laundering and Terrorist Financing: Director Blanco’s Remarks at NYU Law

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On June 12, 2019, Kenneth A. Blanco, Director of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), provided remarks at the NYU Law Program on Corporate Compliance and Enforcement that underscored the agency’s...more

Ballard Spahr LLP

FinCEN Again Extends Real Estate GTOs

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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

Foodman CPAs & Advisors

Residential Real Property Purchased with Virtual Currency must be Reported

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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

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

U.K. Regulator Critiques Legal Industry AML Compliance

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In its “Risk Outlook, Autumn Update” (“Update”) released last week, the Solicitor Regulation Authority (“SRA”), a regulator of solicitors and law firms in England and Wales, found that although the legal sector remains at...more

Foodman CPAs & Advisors

New GTO covers Wire Transfers

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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

Cadwalader, Wickersham & Taft LLP

FinCEN Issues New Geographic Targeting Order for Shell Companies Purchasing High-End Residential Real Estate

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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

Fox Rothschild LLP

FinCEN’s Revised GTOs Expand Real Estate Money Laundering Crackdown To Hawaii, Close “Wire Transfer” Loophole

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This article is Part I of a series in which we address the U.S. government’s attempts to combat money laundering in real estate transactions. This week the Treasury Department’s Financial Crimes Enforcement Network...more

Holland & Knight LLP

West Coast Real Estate Update: March 2017

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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

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