Money Laundering, All-Cash Residential Real Estate Transactions and the Department of the Treasury!
In August 2016 Hallmark Abstract Service provided an overview of the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) disclosure rules, designed to determine who the true underlying buyers were in certain all-cash real estate transactions around the country.
These transactions would occur in designated locations and be over a specific purchase price level (See ‘FinCEN Disclosures (Geographic Targeting Orders) For Cash Real Estate Transactions Expanded‘)!
The concern was then, and remains today, that these transactions utilizing an LLC or some other structure can sometimes be trying to mask the true identity of the purchaser(s) for a variety of purposes including money laundering.
This is the prior list of cities involved along with the purchase price thresholds…
New York: Manhattan with a threshold at $3 million; Brooklyn, Queens, Bronx, and Staten Island at $1.5 million.
Florida: Miami-Dade County, Broward County, and Palm Beach County, all at $1 million.
California: San Diego County and Los Angeles County; plus in the Bay Area, San Francisco, San Mateo County, and Santa Clara County, all at $2 million.
Texas: Bexar County (San Antonio area) with a threshold of $500,000…‘
Summary of the new August 2017 FinCen Geographic Targeting Order Extension
- Who is your underwriter?
- What is the claims experience of your title insurance provider?
- Do you know whether the non-title insurance premium fees you are paying are fair and reasonable?