IS ANYONE PUTTING MIAMI'S MULTI-MILLION DOLLAR LUXURY CONDOMINIUM BUYERS UNDER A MICROSCOPE?

If you are paying attention to the huge number of branded ultra-high luxury condominiums going up like mad in Downtown Miami, and in its Brickell Avenue financial/residential district, between now and 2030, you are wondering aloud just how many of these units, most of which start at $3.5 million and up, must be cash purchases, which are now in the spotlight due to FinCEN's upcoming regulation affecting residential real estate, making the entire United States one big Geographical Targeting Order (GTO).

I know that if I was still in the laundering game, and remembering that everything in Miami is cyclical (in the 1980s, Miami went through a similar Brickell Avenue building boom), you can bet money that professionals who still toil in that dark and sordid business have come up with some extremely inventive and imaginative workarounds to evade not only the letter of the impending FinCEN regs, but the spirit of them as well. Think the use of foreign "financial institutions" as closing agents which are, in truth and in fact, captives of the laundrymen setting up those deals. Think bogus financing arrangements cleverly structured to artfully blend in with the legitimate closings, but which feature under-the-table cash payments that developers anxious to repay massive and expensive construction loans forthwith. Think tricks that have not yet been invented yet in finance, but which are taken from covert tactics in non-financial industries to hide capital.

In short, U.S. law enforcement should set up a task force in South Florida, mich like the one under then-Vice President George HW Bush in the 1980s, to catch the dirty money, before it is invested in those expensive condos. Otherwise, like the expensive oceanfront buildings on Miami Beach, dirty money will end up cleaned and dried in our Downtown structures, and some of our banks will subsequently pay the price for not catching the bad actors timely.