On Dec. 6, 2021, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an advance notice of proposed rulemaking (ANPRM) to solicit public comment on potential requirements under the Bank Secrecy Act (BSA) for certain persons involved in real estate transactions to collect, report, and retain information.
John Kaufmann, Of Counsel at Greenberg Traurig, has authored an article titled “Caveat Re-Emptor” for Volume 15, Issue 1 of CCH’s Journal of Taxation of Financial Products. The article examines the treatment of both “capital markets repos” (i.e., sale-repurchase transactions entered into with respect to liquid property, using standard documentation) and what