THE IMPACT OF THE US TREASURY PILOT PROGRAMME ON STEMMING THE TIDE OF DIRTY MONEY INTO US REAL ESTATE

On 7 March, the Brookings Institute published a Working Paper about problems with people buying US property using shell companies which gave them anonymity.  It says that real estate markets in countries like the US and UK have become prime destinations for illicit wealth.  Real estate is an attractive investment for money launderers: It offers a safe return, the uncertainty around its true market value makes it useful for hiding illicit proceeds, and in many countries the sector is often subject to few, if any, AML provisions.  One report, using only known laundering cases, estimated that at least $2.3 billion was laundered through US real estate 2015-2020.  Since January 2016, in response to the threat that money laundering poses to the real estate sector, FinCEN had been operating its real estate Geographic Targeting Order (GTO) program in certain areas.  The Paper asks whether the GTO program led to deterrence effects in the 22 American counties where it was introduced. 

https://www.brookings.edu/blog/up-front/2022/03/07/the-impact-of-treasurys-pilot-program-on-stemming-the-tide-of-dirty-money-into-us-real-estate

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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