Miami by Ines Hegedus-Garcia

The New York Times and other news outlets recently reported that the U.S. Treasury Department will require title companies to report the identity of the “true beneficial owner” of any entity that purchases luxury, residential real estate in an all-cash transaction in Miami or New York City. The reports mention that this test run could become a permanent requirement across the country and that other real estate professionals (such as real estate agents, lawyers, bankers, etc.) may become the subject of future investigations.  The Treasury Department has stated that this move is aimed to combat money laundering by corrupt foreign officials and transnational criminals, and it comes at a time when the U.S. government is requiring greater disclosure from foreign real estate investors.  For instance, in late 2014, the Bureau of Economic Analysis (BEA) reinstated its requirement that certain foreign investors file a disclosure form (known as a BE-13 form) disclosing the nature and extent of their investments in U.S. real estate or other U.S. business enterprises.   It will be interesting to see whether these new Treasury Department reporting requirements will spread to other real estate investments or whether agencies like the BEA will expand the scope of the information that they collect.