CEA Legislative Update - July 2025
Financial Crimes Enforcement Network (FinCEN) Anti Money Laundering (AML) Ruling of 2024 - UPDATE
Background: On December 1, 2025 all Settlement Agents will be required to comply with the Anti Money Laundering (AML) Ruling put forth by Financial Crime Enforcement Network aka FinCEN. Here is a summary of the August 2024 ruling https://www.federalregister.gov/documents/2024/08/29/2024-19198/anti-money-laundering-regulations-for-residential-real-estate-transfers
CEA and EIC constructed a joint response to FinCEN in January, 2025 setting out our reasons for opposition to the burdens the new rule would place upon escrow practitioners. FinCEN responded to comments made. In June, FinCEN again requested comments on the new rule. Again, CEA and EIC responded to their request for comments with a new response.
A link to the rule is above. Below are links to the request for comments and both joint responses by CEA and EIC and our Article sent to our membership in May, 2025:
Joint Article to CEA membership in May 2025
Joint Response to FinCEN by CEA and EIC in January 2025
Joint Response to FinCEN by CEA and EIC in July 2025
FinCEN rule and responses to previous request for comments (From the Federal Register website) June, 2025 LINK
Legislative Update
Dancing in the Dark With apologies to Bruce Springsteen, whose 1984 song title echoed a proverb from many centuries prior, in this context we are not talking about songwriting, but instead about toiling in the dark on the far more mundane task of writing a state budget for California. Let us explain. Michael D. Belote, Esq.
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