FinCEN Seeks Comment On Additional AML Regulations For Real Estate Transactions

In an Advance Notice of Proposed Rulemaking ("ANPR"), FinCEN asserted that "the systemic money laundering vulnerabilities presented by the U.S. real estate sector, and consequently, the ability of illicit actors to launder criminal proceeds through the purchase of real estate, threatens U.S. national security and the integrity of the U.S. financial system." FinCEN seeks comment on, among other things:

• the geographic scope of additional regulations;
• who should be subject to such regulations;
• what types of real estate purchases should be subject to such regulations;
• what information should be reported and retained; and
• what an "appropriate" dollar-value threshold would be to trigger reporting requirements.