> The rules cover properties purchased for more than $3 million in Manhattan, properties over $1 million in the southern Florida locations, over $2 million in the California locations and more than $3 million in the Hawaii locations.
> Treasury said that among the transactions covered by the rules over the past year "about 30 percent... involve a beneficial owner or purchaser representative that was also the subject of a previous suspicious activity report."
It makes you wonder how much the real estate market is inflated due to money laundering and foreign funds flowing in for washing or investments, keeping real customers out of the market.
Fact is money laundering is a problem in real-estate, art, crypto, political campaigns [2] (with Citizens United) and more.
[1] https://www.cnbc.com/2017/08/24/a-third-of-luxe-real-estate-...
[2] https://theintercept.com/2016/08/03/citizens-united-foreign-...
OH come on.
Bank tellers file suspicious activity reports for any arbitrary reason. The only people these SARs ensnare are poor-ish people that accidentally structured a cash transaction and it looked like they were trying to avoid the $10,000 reporting threshold. I've read enough appeals court cases to see that it doesn't catch actual money laundering from illicit sources.
And with the real estate industry successfully lobbying Congress from an exemption to anti-money laundering laws, I don't think these wealthy people will ever be investigated from a "Suspicious Activity Report" since there isn't a legal framework to further investigate.
> Treasury this week expanded and extended a program targeting luxury real estate deals in New York, Miami, Los Angeles and other big markets to prevent the use of real estate for money-laundering by overseas buyers. The program was designed to prevent buyers from using shell company's or LLC's to hide the identities of the real buyers.
The federal government doesn't regulate what kind of business entities their states offer. And you can always use a lawyer on the incorporation forms if that state asks for more info and have your whole entity protected by client attorney privilege.
There's no probable cause to raid the lawyer, and the money is magically clean in the property now.
There are so many issues with conclusions like this but the simplest question to ask first is, "What's the SAR rate for the equivalent tronche of people who aren't involved in money laundering?". This analysis probably suffers from Berkson's Paradox: https://www.youtube.com/watch?v=daiEkxSaRlU