Effective March 23, 2026, Land Title has paused all FinCEN data collection and reporting.
The FinCEN Anti-Money Laundering (AML) reporting requirements, which originally took effect on March 1, 2026, are currently suspended.
Due to a federal court ruling, the Treasury issued a statement on March 20, 2026, announcing the suspension of the requirement for reporting persons to file Real Estate Reports (RER) with FinCEN:
“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 this means for you:
- No Required Information: Land Title will not require impacted parties to provide any new information under the FinCEN ruling as long as the reporting pause is in place.
- Data Handling: If a party has already submitted this information to Land Title, we will delete it from our records 30 days after the transaction closing date, provided no new court rulings or FinCEN guidance is issued in the interim.
- Optional Submission: While not required, a buyer or seller may still choose to submit their information if they prefer it to be on file in the event of future regulatory changes.
This is a rapidly shifting landscape and Land Title will continue to monitor the issues closely.