FATF on Money Laundering and Terrorist Financing Through the Real Estate Sector

The Financial Action Task Force published their report on Money Laundering & Terrorist Financing Thorugh the Real Estate Sector (June 29, 2007). I was disappointed in the report. I have a history of structuring complex real estate transactions. The report did little to help distinguish between legitimate and illegitimate structures. All of the structures and … Read more »

Effects of FinCEN’s Withdrawal of Rule-Making on Anti-Money Laundering

Last week, FinCEN withdrew a proposed rulemaking for anti-moneylaundering procedures for unregistered investment companies. [See: FinCEN Withdraws Proposed Rulemaking for Unregistered Investment Companies] FinCEN warned that they have not abandoned plans for rule-making. They merely felt that after six years the notice had gone stale. FinCEN may come out with AML program rule proposal, but would … Read more »