Soflo Consulting AML training for real estate professionals — GTO and BSA compliance certification program
AML Training Center
Real Estate & Title Companies

AML Training Built for
Real Estate & Title Companies

Stay ahead of FinCEN GTOs, 31 CFR Part 1031 requirements, and beneficial ownership rules with training built for your industry.

Instant access
Self-paced online training
Verifiable certificates
Documented training records
Real Estate-Specific Risks

Why Real Estate Is a Top Money Laundering Target

Real estate transactions are among the most common vehicles for laundering illicit funds. Your team needs to know what to look for.

All-Cash Purchases

Properties purchased without financing are a primary vehicle for real estate money laundering - no lender due diligence to catch red flags.

Shell Entity Buyers

LLCs, trusts, and other legal entities used to obscure the true beneficial owner of a property.

Wire Fraud & Diversion

Fraudulent wire instructions intercepted or fabricated to redirect closing funds to criminal accounts.

Beneficial Ownership Gaps

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.

Was Your Market Covered by a Real Estate GTO?

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.

View GTO Map
Soflo Consulting real estate AML compliance training dashboard showing course modules and certificate tracking
Regulatory Requirements

What Title Companies Must Comply With

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.

Choose Your Training Plan

All plans include instant access, NAMLC-verified certificates, and annual renewal tracking.

Training Only

Self-Paced Online Training

Annual AML/BSA training and certification. Certificates verified through NAMLC.com.

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Most Popular

Training + Policy Review

Self-Paced Online Training

Training plus expert review of your existing AML documents.

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Full Program Creation

Self-Paced Online Training

Complete build-out of your BSA/AML program from scratch.

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Real Estate AML Training - FAQ

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.

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.

Get Your Title Team GTO-Ready

Industry-specific training. Instant access. Verifiable certificates. No mandatory sales call.