
Stay ahead of FinCEN GTOs, 31 CFR Part 1031 requirements, and beneficial ownership rules with training built for your industry.
Real estate transactions are among the most common vehicles for laundering illicit funds. Your team needs to know what to look for.
Properties purchased without financing are a primary vehicle for real estate money laundering - no lender due diligence to catch red flags.
LLCs, trusts, and other legal entities used to obscure the true beneficial owner of a property.
Fraudulent wire instructions intercepted or fabricated to redirect closing funds to criminal accounts.
Shell entities and nominee buyers can hide who really owns a property. Verifying beneficial ownership and source of funds on all-cash purchases remains best practice even after the residential real estate GTOs expired on February 28, 2026.
FinCEN's residential real estate Geographic Targeting Orders covered dozens of markets across the US until they expired on February 28, 2026. Those reporting obligations no longer apply, so beneficial ownership and source-of-funds review on all-cash purchases is now best practice rather than a mandate. Explore our GTO map for current MSB orders and the historical real estate record.

FinCEN Geographic Targeting Orders (GTOs)
Until February 28, 2026, title companies in covered markets were required to collect and report beneficial ownership information on all-cash residential purchases above the threshold. Those GTOs expired and were not renewed; beneficial ownership review remains best practice.
31 CFR Part 1031 (Title Companies)
Title and settlement companies are not currently required to maintain a BSA AML program. Many keep a voluntary program because underwriters, lenders and banking partners expect one.
SAR Filing for Real Estate
Title and settlement companies have no SAR filing requirement. FinCEN's FAQs for the now-vacated Residential Real Estate Rule (L.4–L.5) explain that reporting persons may file SARs voluntarily, and anyone may still file a voluntary SAR through BSA E-Filing.
Beneficial Ownership Collection
Identifying and documenting the true beneficial owner behind shell entity purchases is a core compliance requirement.
All plans include instant access, NAMLC-verified certificates, and annual renewal tracking.
Annual AML/BSA training and certification. Certificates verified through NAMLC.com.
Select PlanTraining plus expert review of your existing AML documents.
Select PlanComplete build-out of your BSA/AML program from scratch.
Select PlanTitle and settlement companies are not currently required to maintain a BSA AML program. Many keep a voluntary program because underwriters, lenders and banking partners expect one.
FinCEN's residential real estate GTOs required title companies in covered markets to collect and report beneficial ownership information on all-cash residential purchases above the applicable threshold. Those orders expired on February 28, 2026 and were not renewed, and the replacement nationwide rule is currently blocked in court - so no real estate report is required right now. Beneficial ownership and source-of-funds review remain best practice, and our training keeps your team current.
Real estate agents have no BSA program requirement today, and FinCEN's Residential Real Estate Rule was vacated on March 19, 2026, and is on appeal. Training is voluntary, but it helps agents spot red flags and meet Form 8300 and OFAC duties.
Training Only covers annual employee certification. Full Program Creation includes a custom AML policy manual, risk assessment, and beneficial ownership procedures tailored to your title company's specific operations, with training in beneficial ownership and source-of-funds review for all-cash buyers.
AML training addresses financial crime compliance, but employees are also frequently targeted through phishing, executive impersonation, wire fraud, credential theft, and AI-generated scams. These practical courses, delivered through Simple Training Center, round out your annual employee compliance training.
Explore Additional TrainingDelivered through SimpleTrainingCenter.com, Soflo Consulting's online training platform.
Executive Wire Fraud Prevention
Help employees identify executive impersonation, fraudulent wire requests, vendor payment changes, business email compromise, and verification failures.
Cybersecurity Awareness
Practical annual cybersecurity awareness training for employees handling company systems, customer data, financial information, and business communications.
Phishing & Social Engineering
Teach employees how to recognize phishing, impersonation, credential theft, social engineering, and suspicious requests.
Deepfake Defense
Train employees and executives to recognize AI-generated voice, video, and identity impersonation used in financial fraud.
Data Privacy & Information Handling
Train employees to properly handle customer information, confidential records, personal data, file sharing, retention, and accidental disclosures.
Industry-specific training. Instant access. Verifiable certificates. No mandatory sales call.