MORT-BO-002Critical Risk
beneficial ownership
Red Flag
Real estate purchase is financed through a nominee borrower or straw buyer, where the true purchaser is a foreign PEP or sanctioned individual attempting to conceal their identity.
Industry
Mortgage Companies
Transaction Type
other
Customer Type
legal entity
Category
Regulatory Source
Document:Kleptocracy Advisory
Type:FinCEN Advisory
CFR Citation:31 CFR §1010.230
SAR Category:Beneficial ownership
FinCEN Key Term:Straw Buyer
Last Verified:2026-04-15
This red flag is provided for informational and educational purposes only. It is not legal, regulatory, or compliance advice. Always consult the official source document and a qualified compliance professional for guidance specific to your situation.