FinCEN Rule Targets Money Laundering in All-Cash Home Deals

Written by Lexx Thornton

The U.S. Treasury Department’s financial crime-fighting arm has introduced a new rule aimed at cracking down on money laundering in all-cash home purchases, but everyday buyers shouldn’t be alarmed. The federal regulation, formally known as the “Anti-Money Laundering Regulations for Residential Real Estate Transfers,” requires mandatory reporting of all-cash residential real estate transactions involving trusts, estates, limited liability companies (LLCs), corporations, and partnerships to the Financial Crimes Enforcement Network (FinCEN). 

The language of the rule makes it clear that it does not apply to property purchases in which the buyer is an individual. In other words, a house hunter looking to buy a $500,000 single-family home without a mortgage will not be expected to report the deal to the Department of the Treasury headed by Secretary Scott Bessent. 

“The rule is very targeted, focusing on high-risk all-cash entity or trust transactions, not the broader residential market,” stresses Realtor.com® senior economic research analyst Hannah Jones. 

Originally unveiled a little over a year ago, the new FinCEN rule will go into effect on Dec. 1, 2025. 

The aim of the provision, as laid out in an online summary, is “to curtail the ability of illicit actors to anonymously launder illicit proceeds through transfers of residential real property, which threatens U.S. economic and national security.” 

Simply put, FinCEN is seeking to make it harder for criminals using legal entities like trusts and LLCs to launder misbegotten funds through all-cash home purchases while keeping their identities shielded.

“This new rule introduces heightened compliance costs, more transparency, and could disrupt illicit activity, but should not impact typical home sales or most all-cash purchases by individuals,” explains Jones. “Over time, it should reduce the use of opaque legal structures for money laundering, while keeping the mainstream residential market largely unaffected.” 

The regulation, however, does directly affect settlement agents, title insurance companies and agents, escrow agents, and attorneys, who will be responsible for reporting to FinCEN “high-risk” all-cash transfers of residential real estate. 

Echoing Jones’ words, Ana Bozovic, a Miami-based real estate agent and founder of Analytics Miami, says wealthy buyers-those most likely to use trusts and LLCs-should be able to comply with the new reporting requirement with relative ease. 

“This new FinCEN rule creates more procedural complexity, but at the very high end buyers can easily afford the legal and advisory support to navigate it,” she tells Realtor.com. Bozovic says that in Miami, 80% of sales involving expensive properties priced at more than $2,000 per square foot through the second quarter of 2025 were all-cash. 

“The main point is this: The high-end, all-cash buyers are not coming to Miami to launder money,” she adds. “This logic applies to end users and to investors. They are coming because they have legitimate wealth that they want to diversify out of hostile jurisdictions and because they want to improve their quality of life. The new FinCEN rule does not alter this reality.”