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Office of the
Illinois Attorney General
Kwame Raoul

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April 24, 2024

Chicago – Attorney General Kwame Raoul joined a coalition of 24 attorneys general in filing a letter with the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) in support of proposed rules entitled “Anti-Money Laundering Regulations for Residential Real Estate Transactions.”

In the letter, Raoul and the coalition express support for the regulations, which will reduce criminals’ ability to launder money through residential real estate transactions. Specifically, the proposal requires “certain persons involved in real estate closing and settlements to submit reports and keep records on identified non-financed transfers of residential real property to specified legal entities and trusts on a nationwide basis.” 

“These proposed regulations would help deter the use of real estate transactions to hide criminal activity,” Raoul said. “I will continue to work with my fellow attorneys general to provide law enforcement with the tools necessary to investigate and prosecute financial crimes.” 

The proposed regulations will: 

  • Require businesses – including attorneys – performing closing or settlement functions, for a non-financed sale or transfer of residential property to any entity or trust, to collect and report information to FinCEN.
  • Permit federal, state, and local law enforcement to access more information about suspicious real estate transactions more efficiently from a single source.
  • Aid law enforcement in identifying suspicious real estate transactions on a national basis that may otherwise remain undetected. 

The letter also explains that the proposed rule is not overly burdensome in its reporting requirements. FinCEN will continue to exempt those involved in real estate closings and settlements from the Bank Security Act’s requirement to establish anti-money laundering programs. Additionally, certain transfers will not be subject to the reporting requirements. 

Joining Raoul in filing today’s comment are the attorneys general of Alaska, Arizona, California, Colorado, Delaware, the District of Columbia, Hawaii, Maine, Maryland, Minnesota, Nebraska, Nevada, New Hampshire, New Jersey, New Mexico, New York, Oklahoma, Pennsylvania, Rhode Island, South Dakota, Tennessee, Vermont and the U.S. Virgin Islands.