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In February 2022, CDIA filed a comment to FinCEN in response to its Advance Notice of Proposed Rulemaking (“ANPRM”) concerning the implementation of the Bank Secrecy Act (“BSA”) requirements relating to the collection, reporting, and retention of information pertaining to potential money laundering associated with non-financed real estate transactions.
In December 2021, the Financial Crimes Enforcement Network (FinCEN) issued an ANPR “on a potential rule to address the vulnerability of the U.S. real estate market to money laundering and other illicit activity. The systemic money laundering vulnerabilities presented by the U.S. real estate sector, and consequently, the ability of illicit actors to launder criminal proceeds through the purchase of real estate, threatens U.S. national security and the integrity of the U.S. financial system.” The ANPR was covered by a press release.