December 12, 2025 10:21 pm

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New reporting rule on all-cash real estate purchases by LLCs and Trusts takes effect March 1, 2026

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has officially postponed the reporting requirements of its landmark Residential Real Estate Rule until March 1, 2026, granting the real estate sector additional time to adapt to the anti-money laundering measures. The rule, finalized in August 2024, would have taken effect December 1, 2025, but FinCEN on September 30, 2025, issued an exemptive relief order postponing the enforcement to 2026.

real estate rule

Designed to pierce the veil of anonymity in high-risk property transactions, the rule targets non-financed (all-cash) transfers of U.S. residential real estate to legal entities such as LLCs or trusts. These deals, often favored by illicit actors to launder proceeds from corruption, narcotrafficking, and fraud, have long evaded scrutiny due to the absence of traditional bank financing.

By bolstering transparency, the rule aims to empower law enforcement with actionable data and curbing money laundering.

Starting March 1, 2026, professionals involved in real estate closings and settlements—including title insurance companies, settlement agents, and attorneys—must submit detailed reports to FinCEN. Required disclosures include the beneficial owners of purchasing entities, funding sources, transaction details, and property specifics, such as single-family homes, condos, townhouses, or cooperatives.

The reports will be due by the end of the month following closing or within 30 days of the transaction, whichever is later. Exemptions apply to transfers to individuals or certain financed purchases, focusing solely on those deemed vulnerable to abuse.

FinCEN’s issued the extension following requests from industry groups for more preparation time to develop compliance systems and train staff.

Mario Lotmore
Author: Mario Lotmore

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