ALTA Develops Forms to Aid Compliance With FinCEN AML Rule

June 24, 2025


TitleNews Online

ALTA has developed two forms to assist the industry in collecting information needed to comply with FinCEN's Anti-Money Laundering (AML) rule for residential real estate transactions.
ALTA’s AML Work Group developed collection forms for buyers and sellers. The forms are designed to take advantage of the reasonable reliance standard in the rule. It also includes a certification section copied from a model FinCEN developed for bank compliance with the customer due diligence rule.
The buyer’s form includes sections to collect information about:
  • the person completing the form
  • potential exemptions to reporting
  • the buyer/transferee in a covered real estate transaction
  • the origin of funds used to acquire the subject real estate
The seller’s form includes sections to collect information about:
  • the person completing this collection form
  • potential exempt transactions
  • the seller in a covered real estate transaction
Earlier this month, FinCEN issued a 30-day comment period to changes made to its collection form real estate professionals will use to submit information about reportable transactions. The comment period ends July 7.
The rule goes into effect Dec. 1.


Contact ALTA at 202-296-3671 or [email protected].