It appears that America's powerful real estate Special Interests can no longer bully FinCEN around. The anti-money laundering agency this week FINALLY to action to require reporting of cash purchases on real estate, after decades of dithering around. Whether the delay was due to improper Congressional influence upon the agency, due to repeated campaign contributions we cannot prove, but the day will come later in 2024 when closing agents, be they lawyers or title companies, will be required to file what is being labeled The Real Estate Report, on all cash residential real estate transactions.
The new regulation, which essentially extends the current area-specific GTOs to the entire United States, will give law enforcement a new and valuable tool to start closing the existing loopholes in real estate money laundering. Expect the Public Comments, by the country's real estate sales industry, as well as some developers, to be brutal, claiming excessive and expensive, as well as delaying consequences. Don't give in to those Special interests, FinCEN, for residential real estate money laundering is one of the principal domestic techniques of laundrymen to integrate dirty money into our legitimate economy, and of all people, I should know.
Compliance officers: Expect money launderers to take large amounts of client funds and make cash purchases now and during the period before the regulations take effect, and govern yourselves accordingly. Any such purchase activity, which appears to have not been regularly occurring for at least the past year, requires enhanced due diligence, to rule out real estate money laundering; Watch for it.
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