Cadwalader attorneys analyzed the recent Geographic Targeting Order issued by the FinCEN. The Order is part of FinCEN's ongoing efforts to "combat money laundering within the real estate sector."
The Financial Crimes Enforcement Network ("FinCEN") expanded its efforts to combat money laundering in the luxury residential real estate market. FinCen also issued guidance on the risks associated with "all-cash" transactions in that market.
Cadwalader attorneys reviewed FinCEN's expansion of the number of locales in which it will use Geographic Targeting Orders to temporarily require U.S. title insurance companies to identify the "beneficial owners" behind the legal entities used to make "all-cash" purchases of high-end residential real estate.