The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has long recognized non-financed (i.e., “all-cash”) transfers of residential real estate as susceptible of money laundering because these methods of payment tend to evade scrutiny by financial institutions subject to the Bank Secrecy Act of 1970 (BSA) and anti-money laundering (AML) program obligations and subject to Suspicious Activity Report (SAR) filing requirements.
FinCEN Proposes Rulemaking Imposing New Residential Real Estate Reporting Requirements
