ARTICLE
8 February 2022

FinCEN Extends Comment Deadline For ANPR On Real Estate Transactions

CW
Cadwalader, Wickersham & Taft LLP

Contributor

Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
Comments are now due by February 21, 2022.
United States Finance and Banking

FinCEN extended the comment period for a proposed rulemaking concerning potential Bank Secrecy Act information collection and reporting requirements "on certain persons participating in transactions involving non-financed purchases of real estate."

As previously covered, the Advance Notice of Proposed Rulemaking ("ANPR") addresses "the systemic money laundering vulnerabilities presented by the U.S. real estate sector," specifically, "the ability of illicit actors to launder criminal proceeds through the purchase of real estate."

Comments are now due by February 21, 2022.

Primary Sources

  1. FinCEN Press Release: FinCEN Announces Extension of the Comment Period for Its Real Estate Advance Notice of Proposed Rulemaking

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