FinCEN Issues Filing Guidance for AML Rule

December 19, 2025

FinCEN published resources Dec. 19 to aid title and settlement professionals comply with reporting requirements imposed by the agency’s anti-money laundering (AML) rule for residential properties, which goes into effect March 1, 2026.

The resources include:

  • Real Estate Report Filing Instructions: A step-by-step guide for the Real Estate Report form fields.
  • Technical Specifications for Batch XML Filers: A technical guide to batch filing, including how to format the Real Estate Report in a batch XML.
  • Real Estate Report PDF Filing Instructions: A quick reference guide to filing the Real Estate Report as a PDF.

“FinCEN’s release of compliance resources is a helpful first step for real estate professionals as they prepare to implement the Residential Real Estate Rule," said ALTA CEO Chris Morton. "However, significant work remains ahead of us to ensure that title and settlement companies—many of which are small businesses—have the clarity, tools and lead time necessary to operationalize these requirements before the rule’s effective date. Continued engagement, clear implementation guidance and practical compliance resources will be critical to ensuring a smooth and effective rollout.” 

ALTA Resources

ALTA has developed resources to help industry professionals comply with the rule.

  • Collection Forms: ALTA has developed buyer and seller forms to assist industry professionals in collecting information needed to comply with the rule. Click here to access the forms. You must be logged in and be an ALTA member or a policy forms licensee to access these collection forms.
  • FAQs: ALTA has compiled a list of FAQs that address the basics, reportable transactions, who must report; information regarding the reporting person, the transferee, the transferor, payments, and hard money, private and other similar loans; reasonable reliance; and filing procedures. The FAQs are only available to ALTA members.
Bootcamp

To help professionals prepare for the rule, ALTA is offering a two-day virtual bootcamp on Jan. 22-23.

The bootcamp will provide:

  • Insights into how companies are structuring reporting workflows
  • A breakdown of the rule’s 111+ data points
  • Common pitfalls to avoid
  • Smart tools to train your team with confidence
  • Guidance for communicating clearly with customers and reducing confusion
  • A framework for reviewing new technology and services to help with reporting

Click here to register for the bootcamp. 


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