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Q: What types of anti-money laundering risks are most common with real estate and mortgage transactions?
Although not required to by regulation, FinCEN encourages real estate brokers, escrow agents, titles insurers and other real estate professionals to voluntarily report suspicious transactions. Mortgage lenders should speak with their third party vendors and business partners about the dangers of money laundering and encourage them to report any suspicious activity to them if it involves a transaction that both parties are involved in.
It is important for mortgage lenders to maintain an AML Program that meets regulatory requirements. This includes, but is not limited to, performing AML risk assessments and independent audits of the Program at least every 12-18 months.
The FinCEN Advisory (FIN-2017-A003) referenced in this article may be found at: https://www.fincen.gov/sites/default/files/advisory/2017-08-22/Risk%20in%20Real%20Estate%20Advisory_FINAL%20508%20Tuesday%20%28002%29.pdf
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