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
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
On December 8, 2021, the Federal Crimes Enforcement Network (“FinCEN”) division of the United States Treasury published an Advance Notice of Proposed Rulemaking (“ANPRM”) (Anti-Money Laundering Regulations for Real Estate...more