The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has long recognized non-financed (i.e., “all-cash”) transfers of residential real estate as susceptible of money laundering because these methods of payment tend to evade scrutiny by financial institutions subject to the Bank Secrecy Act of 1970 (BSA) and anti-money laundering (AML) program obligations and subject to Suspicious Activity Report (SAR) filing requirements.

Continue reading the full GT Alert.

Tags: Financial Regulatory & Compliance, FinCEN, GT Insight, real estate
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Photo of Marina Olman-Pal Marina Olman-Pal

Marina Olman-Pal, Co-Chair of the firm’s Financial, Regulatory & Compliance Practice, advises foreign and U.S. financial institutions on a broad range of regulatory matters including licensing, acquisitions, divestitures, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, and compliance with Office…

Marina Olman-Pal, Co-Chair of the firm’s Financial, Regulatory & Compliance Practice, advises foreign and U.S. financial institutions on a broad range of regulatory matters including licensing, acquisitions, divestitures, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, and compliance with Office of Foreign Assets Control (OFAC) sanctions programs. Marina counsels a wide range of companies in the financial services sector including, domestic and foreign banks, gaming companies, money services businesses including money transmitters, cryptocurrency businesses, Fintech companies and digital payment companies. Throughout her career, Marina has represented clients before U.S. regulators such as the Federal Reserve, OCC, FDIC, FinCEN, OFAC, the Florida Office of Financial Regulation and other state supervisory authorities. Marina also regularly develops anti-money laundering programs for a wide range of financial services businesses and non-financial services businesses including, U.S. and foreign companies active in industries such as real estate, hospitality, automotive and artificial intelligence, among many others.

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Photo of Kyle R. Freeny Kyle R. Freeny

Kyle R. Freeny, a skilled trial attorney and former federal prosecutor for the Special Counsel’s Office and the Department of Justice (DOJ), Criminal Division’s Money Laundering and Asset Recovery Section (MLARS), focuses her practice on white collar criminal defense, government and internal investigations,

…

Kyle R. Freeny, a skilled trial attorney and former federal prosecutor for the Special Counsel’s Office and the Department of Justice (DOJ), Criminal Division’s Money Laundering and Asset Recovery Section (MLARS), focuses her practice on white collar criminal defense, government and internal investigations, and anti-money laundering (AML) and international corruption matters.

Kyle was one of 19 prosecutors selected by Robert S. Mueller III to conduct the high-profile investigation into alleged Russian election interference, coordination between Russian officials and the Trump campaign, and related matters. As Assistant Special Counsel, Kyle played a lead role in federal tax and bank fraud investigations, as well as a money laundering investigation into the funding of Russian intelligence cyber intrusions during the 2016 Presidential election using cryptocurrency.

While at the Department of Justice, Kyle was involved in investigations relating to major international money laundering and corruption matters, including matters involving the Bank Secrecy Act (BSA), Foreign Corrupt Practices Act (FCPA), and foreign banking and corruption laws designated as predicates to U.S. money laundering charges. Kyle has considerable experience handling cross-border issues and coordinating with foreign law enforcement authorities and U.S. and foreign regulators on complex transnational financial cases.

Kyle has also represented dozens of federal agencies in high-profile litigation, including the Office of Foreign Assets Control (OFAC), the Department of Defense, and the Federal Financing Bank. Kyle has appeared before federal trial courts across the country.

‡ Admitted in California. Practice in the District of Columbia limited to matters and proceedings before Federal courts and Agencies.

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Photo of Barbara T. Kaplan Barbara T. Kaplan

Barbara T. Kaplan has been named one of the top 50 women lawyers in New York City by Super Lawyers magazine, and focuses her tax litigation practice on domestic and foreign corporations, partnerships, and individuals in federal, state, and local tax examinations, controversies…

Barbara T. Kaplan has been named one of the top 50 women lawyers in New York City by Super Lawyers magazine, and focuses her tax litigation practice on domestic and foreign corporations, partnerships, and individuals in federal, state, and local tax examinations, controversies and litigation, including administrative and grand jury criminal tax investigations.

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Photo of Claudio J. Arruda Claudio J. Arruda

Claudio J. Arruda advises domestic and international financial services firms and institutions, including banks, broker-dealers, Fintech companies, and investment advisory firms on a broad range of regulatory issues, as well as general corporate matters. He represents these institutions on matters related to the…

Claudio J. Arruda advises domestic and international financial services firms and institutions, including banks, broker-dealers, Fintech companies, and investment advisory firms on a broad range of regulatory issues, as well as general corporate matters. He represents these institutions on matters related to the applicability and compliance with state and federal banking, and consumer laws and regulations.

Claudio also advises a wide range of investment advisers on all aspects of securities regulatory compliance, particularly including new and existing SEC rules, and has experience advising clients on corporate governance and general corporate matters.

In addition, Claudio represents public and private corporations in negotiating cross-border financing projects. He also has experience assisting in securities enforcement matters and FCPA-related investigations at the U.S. Securities and Exchange Commission (SEC).

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Photo of Tiffanie Monplaisir Tiffanie Monplaisir

Tiffanie Monplaisir is a Practice Group Attorney in the Corporate Practice in Greenberg Traurig’s Miami office. She focuses her practice on financial services provider regulation and compliance. Tiffanie counsels U.S. and international financial institutions, non-financial services businesses, and other entities in navigating the

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Tiffanie Monplaisir is a Practice Group Attorney in the Corporate Practice in Greenberg Traurig’s Miami office. She focuses her practice on financial services provider regulation and compliance. Tiffanie counsels U.S. and international financial institutions, non-financial services businesses, and other entities in navigating the complex federal and state regulatory landscape governing payments, lending, licensing, and consumer financial services. Tiffanie’s practice includes advising banks, FinTech and digital payment companies, money services businesses, payment processors, cryptocurrency businesses, and digital asset companies on a wide range of regulatory matters including licensing, crafting innovative solutions for Bank Secrecy Act/Anti-Money Laundering (BSA/AML) and Office of Foreign Assets Control (OFAC) compliance programs and related policies and procedures. Tiffanie also works on nationwide state money transmitter, lending, servicing, and other license acquisition projects.

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