What Anti-Money Laundering Program?
Many real estate professionals are required to implement customer identification and anti-money laundering compliance programs before May 2003. Title III of the October 26, 2001 USA Patriot Act, which was passed to facilitate the detection, prevention, and prosecution of international money laundering and the financing of terrorism, authorized the Secretary of the Treasury to promulgate additional customer identification and anti-money laundering regulations for businesses considered to be “Financial Institutions.” The categories of business required to adopt customer identification and anti-money laundering compliance programs (“Compliance Programs”) include not only banks and savings associations but also “persons engaged in real estate closings and settlements.” The Department of Treasury (“Treasury”) and Financial Crimes Enforcement Network (“FinCEN”) have already adopted Compliance Program regulations for many of the categories of Financial Institutions. The Compliance Program reg
