Senior Counsel | Real Estate
By Omar Qureshi
Associate | Real Estate
As part of an effort to combat money laundering in United States residential real estate transactions, the Financial Crimes Enforcement Network bureau of the United States Department of the Treasury (“FinCEN”) issued a final rule on August 29, 2024 creating reporting requirements for certain persons involved in non-financed transfers of residential real property (the “Rule”). The Rule will be effective as of December 1, 2025 (the “Effective Date”). The Rule was issued after FinCEN solicited feedback to the proposed rule that it issued on February 16, 2024 (the “Proposed Rule”), which we summarized in a prior article. In addition to the discussion of the Rule below, we have also highlighted changes between the Proposed Rule and the Rule.