Anti-Money Laundering: FinCEN Should Enhance Procedures for Implementing and Evaluating Geographic Targeting Orders, Report to Congressional Requesters [open pdf - 2MB]
From the Highlights: "Bad actors seeking to launder money can use legal entities, such as shell companies, to buy real estate without a loan. Doing so potentially can conceal the identities of bad actors and avoid banks' anti-money laundering programs. To better understand this risk and help law enforcement investigate money laundering, FinCEN [Financial Crimes Enforcement Network] issued its real estate GTO [geographic targeting order]. Although GTOs are limited to 180 days, they may be renewed if FinCEN finds reasonable grounds for doing so. Because of concerns about the potential for bad actors to exploit regulatory gaps to launder money through the U.S. real estate market, GAO [Government Accountability Office] was asked to review FinCEN's real estate GTO. This report examines, among other things, the GTO's issuance and renewal, oversight, outreach, and evaluation."
Government Accountability Office: https://www.gao.gov/