The Financial Crimes Enforcement Network (FinCEN) implements and enforces the Bank Secrecy Act (BSA), which has long required financial institutions to prevent and report money laundering and terrorist financing. FinCEN’s anti-money laundering (AML) compliance obligations, which previously only applied to the financial industry, are now looking to expand, as evidenced by FinCEN’s December 2021 Advance Notice of Proposed Rulemaking. That proposal suggests instituting a broader regulatory framework to ensure consistent reporting nationwide and curb illicit financial activities involving non-financed real estate transactions. With the U.S. real estate industry now in regulatory crosshairs, compliance process reviews and risk assessments will also soon be on the horizon.
Because commercial real estate intermediaries often are not financial institutions, they may not be familiar with the intrusive nature of AML information collection and reporting requirements. If you provide legal advice on or participate in commercial real estate transactions, join us for this program and gain a better understanding of the requirements with which brokers, agents, managers, corporate service providers, and other key players will need to comply.
In this one-hour webcast, experienced compliance advisers from Mayer Brown LLP and Guidehouse Inc. will:
- Discuss what types of real estate transactions will be subject to FinCEN’s renewed geographic targeting orders and the implications for title insurance companies
- Explore how FinCEN’s proposed reporting requirements for all non-financed real estate transactions may play out and who would be subject to compliance with the reporting obligations
- Explain which reporting requirements of the Corporate Transparency Act will apply to commercial real estate holding vehicles
- Consider what is next in the short and long term, including recently adopted and proposed regulations