On March 1, 2016, new U.S. anti-money laundering measures aimed at addressing secrecy in the luxury residential real estate market will take effect. The requirements have caused a stir, in part due to a recent undercover exposé that highlighted the role of attorneys in facilitating transactions that result in the introduction of illicit proceeds into the U.S. financial system. As a result, firms and individuals who may represent purchasers of real estate in the affected areas would be well-advised to understand the requirements and consider taking prudent steps to protect themselves against potential scrutiny from U.S. law enforcement authorities.
In this client alert, Richards Kibbe & Orbe attorney Jamie A. Schafer discusses the new requirements and their implications, and recommend steps that firms and individuals should take in anticipation of potential inquiries that may result from the elevated level of scrutiny.