FinCEN has reported that property management, real estate investment, realty, and real estate development companies were the most commonly-reported entities associated with commercial real estate-related money laundering.
The most commonly-reported activity appears to be money laundering to promote tax evasion. There also may be an increasing trend towards using commercial real estate-related accounts to launder money for politically-exposed persons and for promoting informal value transfer systems.
Additionally, FinCEN has issued guidance on real estate-related financial crimes, which include:
•Foreign Use of Counterfeit Funds
•Real Estate Facilitation of Human Trafficking
•Misappropriation of Funds
•Bank Insider Collusion
•Flipping and Straw Buyer Schemes
•Advance Fee Schemes
The Treasury Department's Financial Crimes Enforcement Network added Honolulu Tuesday to a reporting program for real estate deals involving cash transactions. FinCEN also extended reporting requirements for six other metropolitan areas under a data collection program that started in March 2016.