public comment on how it should impose recordkeeping and reporting requirements<\/a> on certain persons involved in all-cash real estate transactions. Comments must be submitted to FinCEN by Feb. 7, 2022.<\/span><\/span><\/p>\nThe requirements contemplated in the 2021 Anti-Money Laundering Regulations for Real Estate Transactions (ANPRM) may be applied nationwide to a broad range of real estate transactions, including commercial real estate transactions.<\/span><\/span><\/p>\nThey also may impose obligations on market participants that currently are not subject to federal anti-money laundering compliance obligations, such as real estate developers, managers, lenders, and investment advisers and investment companies involved in real estate.<\/span><\/span><\/p>\nThe 2021 ANPRM is the first step in the rulemaking process and will most likely be followed by a detailed proposal and a final rule. In this Legal Update, we provide background on FinCEN\u2019s approach to real estate transaction reporting requirements and summarize the 2021 ANPRM.<\/span><\/span><\/p>\nAs discussed further below, potentially affected participants should consider submitting comments on the 2021 ANPRM to encourage FinCEN to draft a detailed proposal that appropriately weighs the goals of preventing money laundering with potentially burdensome compliance obligations.<\/span><\/span><\/p>\n