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7.3.8 Flashcards
Amanda Ukasick
Created on September 21, 2025
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What is the purpose of FinCEN’s proposed Anti-Money Laundering Regulations for Residential Real Estate Transfers?
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To combat money laundering in high-value residential real estate, especially all-cash deals and luxury properties, by increasing oversight and requiring reporting of beneficial owners.
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What information must real estate professionals collect under the proposed FinCEN rule?
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They must identify buyers, verify the source of funds, and report beneficial owners (those owning 25%+ of a legal entity) to detect and prevent money laundering.
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What are the three steps in the money laundering process, and what occurs in each?
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1) Placement – introduce illegal funds into the financial system (e.g., small deposits or money orders). 2) Layering – distance funds from their source via multiple transactions. 3) Integration – make the illicit funds appear legitimate, such as through a real estate purchase.
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How can MLOs mitigate AML risk in real estate transactions?
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By understanding normal transaction progress, identifying unusual patterns, recognizing red flags, verifying funds, and reporting suspicious activity to authorities when necessary.
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