The Financial Crimes Enforcement Network, a bureau of the U.S. Treasury Department, recently issued geographic targeting orders in Miami-Dade County and Manhattan that will require certain insurance title companies to identify and report the “all cash” buyers of high-end residential real estate.

FinCEN issued the orders after growing concerned over the last year that criminals — corrupt foreign officials, narcotics traffickers and others — have hidden behind anonymous limited liability companies and cash purchases of high-end real estate to launder dirty money. The orders will be in effect from March 1 to Aug. 27. I explore why FinCEN likely felt compelled to issue the orders, what to expect will happen next and who should consider retaining legal counsel.

Why FinCEN Acted

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