> I imagine it would raise a few KYC red flags and reporting requirements, of course.

real estate industry is exempt from AML/KYC requirements, they lobbied Congress and won

secondly, you can use a lawyers IOLTA account for these large transactions, its pooled money from all of their clients - usually retainers and settlements - but nothing dictates that limitation. Banks consider them institutional investors that already did KYC. but. I mean. The client could be from anywhere and the lawyers account cant get probable cause on it for just that.

It’s a known gap in the US AML/KYC framework. DOJ and thinktanks and the EU have been aware for at least a decade.