As many of our clients and real estate partners are aware, the Financial Crimes Enforcement Network (FinCEN) has implemented—and paused—various reporting requirements over the years. Now, new federal rules are set to take effect December 1, 2025, requiring the reporting of certain all-cash residential real estate transactions involving entities such as LLCs and trusts. These rules are aimed at combating money laundering and enhancing transparency in the real estate market.
Final guidance and the official reporting form have not yet been released. In the meantime, the Treasury Department has provided a helpful Q&A on real estate-related reporting requirements, available here.
We are closely monitoring the evolving FinCEN requirements and will be fully prepared to guide our clients and professional partners through this latest regulatory update. If you have any questions or need assistance, please don’t hesitate to contact real estate attorney Kevin Dukes.