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EP 64: Cash Buyers, Shell Companies, and FinCEN: The 2025 Compliance Guide for Title Agents

  • 1.  EP 64: Cash Buyers, Shell Companies, and FinCEN: The 2025 Compliance Guide for Title Agents

    Posted 10-01-2025 17:25

    FinCEN has officially dropped the hammer: a sweeping nationwide rule goes into effect December 1, 2025, requiring title professionals to report the real owners behind all-cash entity purchases of residential real estate. In this episode, Zina and Crosby walk you through the why, what, and how—giving you a clear roadmap to stay compliant and confident. If you’ve ever handled a deal involving an LLC, trust, or shell company, you need this breakdown before the deadline hits.

    What you’ll learn from this episode

    • Why FinCEN is targeting real estate and why it affects all agent s, not just banks
    • How the GTO pilot evolved into a permanent nationwide mandate
    • Transactions are covered under the new rule 
    • Who is responsible for filing and what must be reported
    • Civil and criminal penalties for non-compliance and how to avoid them
    • Practical steps to integrate reporting into your existing title workflows

    Resources mentioned in this episode 

    • American Land Title Association
    • FinCEn
    • US Department of the Treasury 

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    Cash Buyers, Shell Companies, and FinCEN: The 2025 Compliance Guide for Title Agents

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    Mo Choumil
    CEO
    Alltech National Title
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    Mo Choumil
    CEO
    Alltech National Title
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    ALTA Marketplace