04/07/2026
On March 19, 2026, the U.S. District Court for the Eastern District of Texas issued a decision in Flowers Title Companies, LLC v. Bessent vacating the FinCEN Anti-Money Laundering Regulations for Residential Real Estate Transfers Rule ("Rule"). Effective immediately, the Rule is vacated and no longer in effect. FinCEN’s website has been updated with an alert stating, “[i]n light of a federal court decision, reporting persons are not currently required to file real estate reports with FinCEN and are not subject to liability if they fail to do so while the order remains in force.”
We will continue to monitor this matter and encourage you to do the same. If you have any questions, then please reach out to our attorneys.