Effective March 1, 2026, there will be 111 new pieces of data required of buyers in real estate who pay cash, use a trust or an entity. Why the requirement? Because the US Government is trying to eliminate money laundering through real estate purchases.
Finding those entities that might be laundering money through the purchase of real estate boils down to how they buy real estate. If they are using cash, a trust or an entity they are more likely to be laundering money. Mortgage companies that have a process in place to eliminate those entities won't fall under the scrutiny of this division of the Treasury. However, if a financed real estate purchase uses an entity not screening buyers for money laundering, those purchases could fall under scrutiny and require data collection. Those buyers using hard money loans, private lenders and seller carrybacks as financing are in required to submit the 111 pieces of data on the form required.
The Financial Crimes Enforcement Network (FinCen) is a divison of the Department of the Treasury. This entity was created in 2016, but was expanded to include real estate in September 30, 2025. Thanks to the government shut down, the actual start date of these requirements was delayed until March 1, 2026. This is a national requirement, not a local requirement.
The amount of the purchase will start at $300,000 for reporting to FinCen.
Real estate agents will be the front end of this requirement, but won't be fined for a buyer's inaction to participate. Real estate agents typically have the best relationship with buyers and can share this new requirement with their buyer clients. But the actual collection of data from the buyer will be the title company. Reporting of this data will be the due at the end of the month following the month of closing. So if you buy real estate with cash, a trust or an entity (LLC), you will be asked to provide 111 data points on a 5+ page form in order to comply. Failure to do so could delay your close of escrow date.
The FBI, CIA will be policing this aspect of financial reporting.
