White Paper

Are You Within Reach of Anti-Money Laundering Enforcement


Tentacles of Money Laundering Schemes Affect Real Estate Investors Worldwide

“The U.S. Treasury Department has signaled the latest focus of its enforcement: real estate ventures with ties to money laundering schemes. Individual real estate investors and companies involved in luxury real estate, real estate development or investment, property management, and escrow or mortgage services around the globe should heed Treasury’s warnings.

Which Real Estate Markets are Targets?

Several real estate markets in the United States and abroad are ripe for Treasury’s picking. In January 2016, the Treasury Department, Financial Crimes Enforcement Network (FinCEN) issued Geographic Targeting Orders for Manhattan, New York and Miami-Dade Country, Florida. Reportedly nearly one in three apartments in midtown Manhattan is unoccupied for at least ten months each year.

The orders seek to create transparency of investments in the areas by requiring certain U.S. title insurance companies to identify all cash buyers of high-end real estate in those markets. Specifically, the orders require identification of the true beneficial owners behind shell companies that pay for high-end real estate in all cash.”

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Lisa Mays is an associate in the Government Contracts, Investigations & International Trade Practice Group in Sheppard Mullin Richter & Hampton LLP's Washington D.C. office. Her practice focuses on international trade compliance and investigations.



Lisa Mays


Lisa Mays is an associate in the Government Contracts, Investigations & International Trade Practice Group in the firm's Washington D.C. office. Ms. Mays’ practice focuses on international trade compliance and investigations. She advises clients on issues relating to anti-corruption; anti-money laundering; the False Claims Act; sanctions regulations on Cuba, Iran, and North Korea; and U.S. export and import controls, including the International Traffic in Arms Regulations and the Export Administration Regulations.

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