This CLE program provides a focused analysis of FinCEN’s Residential Real Estate Reporting Final Rule and its implications for legal and compliance practice. The program begins with an overview of federal anti-money laundering (AML) enforcement, including key statutory frameworks, the role of FinCEN and OFAC, and the use of Geographic Targeting Orders in monitoring real estate transactions.

The panel will examine the scope and structure of the Final Rule, including covered transactions, reporting obligations, applicable exemptions, and critical definitions such as reporting persons and beneficial owners. The program will also address the current legal landscape, including recent judicial developments affecting the enforceability of the rule and FinCEN’s corresponding guidance.

Emphasis will be placed on practical considerations for attorneys and industry professionals, including compliance strategies, risk assessment, and best practices for navigating uncertainty while maintaining preparedness in the event reporting requirements are reinstated.