U.S. Plays Catch-up to Close Long-Standing Gaps in Anti-Money Laundering Laws: Part Two: Focus on Real Estate Transactions

Bruce Ortwine, General Counsel, Americas; Adviser, Global Legal and Compliance; Senior Executive Vice President, Sumitomo Mitsui Trust Bank, Limited

Part One of this Article focused on the U.S. Government’s anti-money laundering/contra terrorist financing (“AML”) efforts, certain deficiencies in the 2001 USA Patriot Act, which was enacted following the terrorist attacks of September 11, and the attempt to correct those deficiencies through passage of the Anti-Money Laundering Act of 2020 (the “2020 Act”). Part One mentioned that the 2020 Act is an enabling piece of legislation requiring that the Financial Crimes Enforcement Network (“FinCEN”) of the U.S. Department of Treasury issue regulations implementing the 2020 Act’s provisions. To date, however, no such regulations have been proposed, let alone implemented though, as discussed below, in December 2021 and pursuant to the 2020 Act, FinCEN did issue an advance notice of proposed rulemaking (“ANPRM”). Part One concluded that, in recognition of the limitations of the 2020 Act, the U.S. Government has undertaken additional steps to enhance its AML efforts. This Part Two will focus on three of those efforts, all involving the purchase of real estate.

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USA Money Laundering Banking & Finance August 2022 Vol.15, No. 60, Summer 2022

Bruce Ortwine

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General Counsel, Americas, Advisor, Global Legal and Compliance for Sumitomo Mitsui Trust Bank, Limited and Sumitomo Mitsui Trust Holdings, Inc.

Sumitomo Mitsui Trust Bank, Limited

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SMTB is the largest trust bank in Asia and a major international bank with offices throughout Asia, Europe and the U.S. Its parent holding company, Sumitomo Mitsui Trust Holdings, Inc. is a financial conglomerate with a variety of financial institution subsidiaries, including in the banking, asset management, real estate brokerage and leasing sectors.

USA Money Laundering Banking & Finance August 2022 Vol.15, No. 60, Summer 2022

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