McDermott Will & Schulte team featured in Real Estate Finance Journal on AML reporting in residential real estate

The Real Estate Finance Journal recently featured Betty Santangelo, Melissa Goldstein, Julian Wise, Sebastian Orozco Segrera, Scott Bowman, and Kyle Hendrix’s review of FinCEN’s final rule extending anti-money laundering reporting requirements to the residential real estate sector. The authors explain that the rule requires a reporting person — often a title company, closing agent, or attorney — to electronically file reports with FinCEN whenever a legal entity or trust, rather than an individual, acquires residential property, with no exemption based on property value or purchase price.

Notably, while the rule technically took effect March 1, 2026, a federal court vacated it weeks later, and compliance remains suspended pending FinCEN’s appeal. As the authors note, industry participants should still understand their potential obligations in case the order is overturned, since the reporting framework — and its civil and criminal penalties — could take effect at any time.

Read more here.