UPDATE: Anti-Money Laundering Rule for Residential Real Estate Transactions – Effective Date Postponed to March 2026
October 20, 2025On July 14, 2025, we issued a publication related to the implementation of the Anti-Money Laundering Regulations for Residential Real Estate Transfers ("Rule") [1] which were to take effect December 1, 2025. On September 30, 2025, the Secretary of the Treasury issued an order [2], postponing the effectiveness of the Rule until March 1, 2026 [3]. We continue to monitor this situation and will keep you updated on any changes to the effectiveness of this Rule.
Click here to read the July 14, 2025 alert.
[1] See 31 CFR 1031.320(a).
[2] Pursuant to the authority set forth in 31 U.S.C. § 5318(a)(7) and 31 CFR § 1010.970(a).
[3] FinCEN Exemptive Relief Order to Delay the Effective Date of the Residential Real Estate Rule, September 30, 2025
For more information on related matters, please contact:
Yariv C. Ben-Ari at +1 212 592 1440 or [email protected]
Maxim M. L. Nowak at +1 212 592 1464 or [email protected]
© 2025 Herrick, Feinstein LLP. HERRICK® is a registered trademark of Herrick, Feinstein LLP. This alert is provided by Herrick, Feinstein LLP to keep its clients and other interested parties informed of current legal developments that may affect or otherwise be of interest to them. The information is not intended as legal advice or legal opinion and should not be construed as such.