In recent years, various governmental entities believe they have identified vulnerabilities in the purchase and sale of U.S. real property, which makes it possible for criminals to take advantage of real estate money-laundering schemes.
It is believed the purchase of real estate, often combined with methods to conceal a purchaser’s identity and source of funds, can allow criminals to take the ill-gotten proceeds and either park the wealth or integrate the proceeds into the legal economy.
Escrow and title companies can do their part to help the appropriate government authorities track certain types of transactions. First, settlement agents may report “cash” payments received into escrow. Next, settlement agents asked to make multiple payments to the same payee under $10,000 may decline. Last, title insurance companies are required to report certain purchases which are covered by a Geographic Targeting Order (GTO).
This year we will explore these topics in detail:
✓ What transactions are covered by the GTO
✓ What is “cash” as defined by the IRS
✓ How to report “cash” received
✓ Appropriate disbursements or risky disbursements
Keep in mind, the Company has extensive policies and procedures for proper compliance with these items. These articles are not meant to replace the Company guidelines. These articles will touch upon a high-level review of requirements that settlement agents may be required to comply with. Enjoy!
The information provided herein does not, and is not intended to, constitute legal advice; instead, all information, and content, in this article are for general informational purposes only. Information in this article may not constitute the most up-to-date legal or other information.
Article provided by contributing author:
Diana Hoffman, Corporate Escrow Administrator
Fidelity National Title Group
National Escrow Administration