I usually write about mortgage or real estate professionals, but since I teach Anti-Money Laundering classes, I thought it would be helpful for all small businesses to know what’s coming. On September 18, 2023 the Financial Crimes Enforcement Network (FinCEN) published the final rules for the new Corporate Transparency Act (CTA). These rules become effective January 1, 2024 and in typical government practice, there is a Small Entity Compliance Guide. This new law is related …
Do you know how money is actually laundered through real estate transactions? Do you know your Anti-Money Laundering (AML) Training Requirements? Between 2015 and 2020, at least $2.3 billion was laundered through US real estate, with estimates by Washington, D.C. think tank Global Financial Integrity (GFI), putting the number much higher. The real estate sector is now coming under increased scrutiny from government regulators and enforcement agencies for its compliance with anti-money laundering and reporting …
FINRA Regulatory Notice 18-19 issued May 11, 2018 expands AML Program requirements to include additional risk-based procedures, or the “fifth pillar” required for AML programs under the new FinCEN CDD Ruling Since all AML programs are customized based upon the size and risk of a Mortgage Lender, Broker or Individual Licensee, the application of the “fifth” pillar must be factored into all programs beginning on May, 11, 2018. Therefore all AML programs must be modified …