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#2263229 - 12/06/21 01:13 PM AML Program Requirements for the Real Estate
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 4,535
New York City
It's only a ANPRM. I am surprised as I thought that FinCEN would have brought in hedge funds first, but this is interesting as well.

https://www.fincen.gov/news/news-re...eal-estate-sector-reporting-requirements
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#2263730 - 12/16/21 07:20 PM Re: AML Program Requirements for the Real Estate ACBbank
Jennifer Offline
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Jennifer
Joined: Dec 2014
Posts: 201
Will this affect banks?

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#2263731 - 12/16/21 07:23 PM Re: AML Program Requirements for the Real Estate ACBbank
edAudit Offline
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edAudit
Joined: Jul 2008
Posts: 4,815
You are here
It does not appear to in this form,
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#2263733 - 12/16/21 07:25 PM Re: AML Program Requirements for the Real Estate ACBbank
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 85,464
Galveston, TX
I am really not sure how a bank gets involved in a cash purchase of real property. Plus the banks already fall under SAR reporting rules for suspicious activity.
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#2263855 - 12/21/21 03:40 PM Re: AML Program Requirements for the Real Estate ACBbank
John Burnett Offline
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John Burnett
Joined: Oct 2000
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Cape Cod
SAR requirements connect banks to these proposed rules for real estate activities. Bankers who keep themselves aware of what other industries have to do for their BSA/AML/CFT requirements will be more attuned to activities that, if seen by a banker, should be reported. For example, if a bank discovers that a large number of its cashier's checks in moderate amounts have been negotiated at the same time and the indorsements suggest they were involved in a real estate transaction involving a huge sum (such as a couple of million dollars), the bank might well wonder why so many small cashier's checks, purchased over several weeks with several different payees appear to have been negotiated in a single real estate deal of such a size. That could trigger a SAR filing.
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#2263856 - 12/21/21 03:49 PM Re: AML Program Requirements for the Real Estate ACBbank
John Burnett Offline
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John Burnett
Joined: Oct 2000
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Cape Cod
Bankers should also watch the development of these rules because banks are involved in real estate transactions from time to time, and they should want to be aware of any regulatory requirement affecting the real estate sector that might affect banks in some way.
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