The recently extended FinCEN Geographic Targeting Order is another step in the right direction, BUT it fails to give the world's money launderers due credit for imagination and innovation, both of which attributes they have in great quantity. Allow me to explain.
By limiting the focus on cash transactions, FinCEN pointed ignore the fact that an adept financial criminal can make a real estate transaction appear to be financed from afar, with all the relevant forms, bells & whistles. What appears to be a foreign lender, or NBFI, can be created, or one bought or controlled, to "finance" a purchase, wire funds in, with the appropriate closing package, and deceive even the most experienced title company, attorney or closing agent.
Therefore, we wonder if FinCEN might consider expanding the GTO to include ALL large real estate sales. Our law enforcement agencies might also want to examine large transactions, in Miami, New York City, and the other high-end metropolitan centers, to see if any were financed from abroad.