FinCEN AML Rule Guidance 12/1/25

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Aug 25
2 min read

Effective December 1, 2025, the Financial Crimes Enforcement Network (FinCEN) has implemented a nationwide reporting requirement for all-cash or non-financed purchases of residential real estate. This rule expands upon the earlier Geographic Targeting Orders (GTOs), which had previously applied only in certain metropolitan areas.

The purpose of this rule is to combat money laundering, terrorist financing, and other illicit financial activity involving real estate.

Who Must Report

The responsibility to file rests with:

• Title Companies, Settlement Agents, and Closing Attorneys involved in the transaction.

Transactions Covered under FinCEN AML Rule

A report must be filed with FinCEN when:• The purchase is made without a loan or financing (all-cash).• Real estate is acquired by an entity (LLC, corporation, partnership, trust, etc.).• Residential property is involved (single-family homes, condos, co-ops, etc.).

Note: Even if the buyer is an individual, any transaction meeting the criteria must be reported.

Required Information

The reporting party must collect and report the following:

Identity of the Purchaser(s) – including beneficial owners of entities.
Property Information – address, legal description, purchase price.
Method of Payment – wire transfer, check, crypto, etc.
Title/Settlement Agent Information – name, company, contact details.

Form to be Completed

The FinCEN “Real Estate Report” (FinCEN Form 111) will be required. This form must be electronically filed through the BSA E-Filing System within 30 days of closing.

Here is a sample of the FinCEN Real Estate Report form (Form 111) for review.

ClosePoint USA LLC will be trained and prepared for this change and will comply with this requirement.

Action Required

Review the new rule and familiarize yourself with Form 111.
Update closing procedures to ensure proper collection of information at closing.
Ensure compliance training is completed by November 15, 2025.
Coordinate with partners to confirm consistent reporting processes.