On September 30, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced that it will postpone reporting requirements of the Anti-Money Laundering Regulations for Residential Real Estate Transfers Rule (RRE Rule) until March 1, 2026. The RRE Rule was previously set to become effective December 1, 2025.

The RRE Rule requires certain persons involved in real estate closings to submit a Real Estate Report (RER) on transfers deemed “high risk,” including non-financed transfers of residential real property to legal entities and trusts. The intent behind the rule is to expose illicit actors exploiting non-financed transfers of real property, including those that pose domestic threats, such as persons engaged in fraud or organized crime, and foreign threats, such as international drug cartels, human traffickers, and corrupt political or business figures. Non-financed transfers to legal entities and trusts heighten the risk that such transfers will be used for illicit purposes. Reporting persons will submit a RER through the BSA E-Filing System  at no charge. For more information on the RRE Rule and its requirements, please view our prior alert here.

FinCEN is implementing this extension to the RRE Rule in an effort to reduce unnecessary compliance burden and ensure effective regulation. The belief is that granting this temporary order for exemptive relief from the reporting requirements is appropriate through March 1, 2026, as this will allow the real estate industry sufficient time to institute policies, procedures, and processes necessary to ensure compliance with the RRE Rule.

We will continue to closely follow updates on FinCEN’s RRE Rule, keeping our clients apprised as new information is released. If you have any questions about the Residential Real Estate Rule, other FinCEN reporting requirements, or real estate transfers, please reach out to Jayne Katherman, Stacey MacNeal or any attorney in Barley Snyder’s Business or Real Estate practice groups.