On April 25, 2023, the U.S. Department of the Treasury issued the 2023 De-risking Strategy, as mandated by Congress in the Anti-Money Laundering Act of 2020. The Strategy examines the phenomenon of financial institutions de-risking and its causes, and it identifies those greatest impacted. In addition, it offers recommended policy options to combat it.

On April 25, 2023, FinCEN published its FinCEN Year in Review for FY 2022. The Year in Review is intended to help stakeholders gain insight into both FinCEN’s efforts to support law enforcement and national security agencies, and how financial information is used.

On April 21, 2023, FinCEN announced the renewal and expansion of its Geographic Targeting Orders (GTOs) that require U.S. title insurance companies to identify the natural persons behind shell companies used in all-cash purchases of residential real estate. The terms of the GTOs are effective beginning April 25, 2023, and ending on October 21, 2023.

On March 30, 2023, FinCEN published a Financial Trend Analysis on patterns and trends identified in Bank Secrecy Act (BSA) data relating to business email compromise (BEC) in the real estate sector in 2020 and 2021. The report contains relevant information for the public, particularly individual homebuyers and the multiple entities involved in real estate transactions.

On March 3, 2023, the IRS issued a consumer alert to warn taxpayers of new scams that urge people to use wage information on a tax return to claim false credits in hopes of getting a big refund. According to the agency, the scheme encourages people to use tax software to manually fill out Form W-2, Wage and Tax Statement, and include false income information to get substantial refunds based on the large amount of withholding.

On March 2, 2023, the Department of Commerce, Department of the Treasury, and Department of Justice issued a Tri-Seal Compliance to constrain the use of third-party intermediaries or transshipment points to circumvent restrictions, disguise the involvement of Specially Designated Nationals and Blocked Persons (SDNs) or parties on the Entity List in transactions, and obscure the true identities of Russian end users. The Compliance Note highlights several of these tactics to assist the private sector in identifying warning signs and implementing appropriate compliance measures.

On March 2, 2023, the OFAC sanctioned eight Mexican companies linked to timeshare fraud on behalf of the Cartel de Jalisco Nueva Generacion (CJNG). A timeshare is a shared ownership model of vacation real estate in which multiple purchasers own allotments of usage in the same property. Timeshare fraud happens when scam artists call sellers of timeshares, posing as a reseller or real estate agent, then claims to have a buyer for the timeshare or guarantees he can sell the timeshare for a good price.

On January 25, 2023, FinCEN issued an alert to financial institutions on potential investments in the U.S. commercial real estate sector by sanctioned Russian elites, oligarchs, their family members, and the entities through which they act. The alert lists potential red flags and typologies involving attempted sanctions evasion in the commercial real estate sector, and reminds financial institutions of their Bank Secrecy Act (BSA) reporting obligations.