News & Analysis as of

AML/CFT Anti-Money Laundering Geographic Targeting Order

Orrick, Herrington & Sutcliffe LLP

FinCEN updates its money reporting requirement min. from $200 to $1K

On September 8, the Treasury through FinCEN issued additional reporting requirements on financial institutions through its Geographic Targeting Order (GTO). This GTO will require certain money services businesses along the...more

Morrison & Foerster LLP

FinCEN Proposes Expanding Residential Real Estate Anti-Money Laundering Rules

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

Cadwalader, Wickersham & Taft LLP

FinCEN’s Proposed Rulemaking: Enhancing Transparency in Residential Real Estate

While many Americans are struggling to achieve the dream of homeownership, there are criminals that abuse the housing market for financial gain. To avoid the scrutiny of financial institutions that have anti-money laundering...more

Holland & Knight LLP

FinCEN Proposal for Nonfinanced Purchases of Residential Real Estate and Gratuitous Transfers

Holland & Knight LLP on

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

Ballard Spahr LLP

FinCEN Renews and Expands GTO

Ballard Spahr LLP on

FinCEN announced on October 20 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

Ballard Spahr LLP

Treasury Report Targets Money Laundering Risks in Real Estate and Gatekeeper Professions

Ballard Spahr LLP on

In its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”), the U.S. Department of Treasury (“Treasury”) has laid out its AML and money laundering enforcement priorities. Last week, we...more

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