Anti-Money Laundering Rules: Ethical Requirements for Attorneys as Reporting Persons

This article explains the requirements of a new anti-money laundering rule that, when effective on March 1, 2026, will require suspicious activity reporting from advisors (including attorneys) who assist clients with certain residential real estate transfers. FinCEN has extended its earlier Geographic Targeting Order for real estate transactions which now expires on February 28, 2026.

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Herrick K. Lidstone is a partner emeritus of Jennings Haug Keleher McLeod Waterfall LLP, where he practices in the areas of business transactions, limited liability company and corporate formation and organization, mergers and acquisitions, ethics, and securities—hkl@jkwlawyers.com. Victoria Bantz is a member of Clark Hill PLC, where she advises clients on business and securities law—vbantz@clarkhill.com.

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