On 11 March 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) to require money services businesses (MSBs) located in specified zip codes of California and Texas to file currency...more
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on March 11, 2025, issued a Geographic Targeting Order (the Southwest GTO) as part of a "whole-of-government approach" to leverage all...more
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued a final rule (the Residential Real Estate Rule) requiring certain persons involved in residential real estate closings and...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
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
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 yesterday 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 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
Meanwhile, Congress Wants a Report on Russian Money Laundering and Its Relationship to the Real Estate Industry FinCEN announced today that, once again, it is extending the Geographic Targeting Order, or GTO, regarding...more
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
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
“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
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
This article is Part II of a series in which we address the U.S. government’s attempts to combat money laundering in real estate transactions....more
In a press release touting recent law enforcement success stories based upon Bank Secrecy Act reporting by financial institutions, the Treasury Department’s Financial Crimes Enforcement Network revealed publicly for the first...more
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
As part of his remarks at the Institute of International Bankers Annual Anti-Money Laundering Seminar, US Financial Crimes Enforcement Network Deputy Director Jamal El-Hindi discussed certain US Department of Treasury efforts...more
In yet another sign of its aggressive campaign to fight money laundering, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) has trained its sights on the high-end real estate market in New York and...more
The Financial Crimes Enforcement Network (FinCEN) recently announced two geographic targeting orders (GTOs) imposing new reporting and recordkeeping requirements on title insurance companies operating in New York City and...more
The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has announced that it is extending its Geographic Targeting Order (GTO) focused on trade-based money laundering schemes in South Florida. When the GTO...more
Continuing its aggressive use of Geographic Targeting Orders (GTOs) to fight money laundering, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced on July 7 that it was renewing a GTO in Southern...more