03/23/2026
From Financial Crimes Enforcement Network: In 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.
What does this mean for you? It will be best practice to continue to collect the information required to report, but the reports do not have to be filed right now. Of course, as with any pending litigation, the situation is fluid. Here is the FinCen website which does appear to be currently updated:
In 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.