A recent federal court decision has temporarily halted a new federal reporting requirement that would have impacted certain real estate transactions.

On March 19, 2026, a U.S. District Court vacated the FinCEN Residential Real Estate AML Rule, determining that the agency exceeded its authority under the Bank Secrecy Act and did not comply with required rulemaking procedures. As a result, the rule has been set aside for now.

The rule, which took effect December 1, 2025, with compliance beginning March 1, 2026, would have required reporting on certain non-financed residential real estate transactions, particularly those involving legal entities or trusts. Its intent was to address potential money laundering risks associated with all-cash purchases.

Following the court’s decision, the Financial Crimes Enforcement Network (FinCEN) has confirmed that reporting is not currently required, and individuals are not subject to penalties for noncompliance while the ruling remains in effect.

At this time, there is no action required from members related to this rule.

However, it is important to note that this situation may evolve. The Department of Justice has not yet indicated whether it will appeal the decision. If an appeal is filed, the court could issue a stay that would temporarily reinstate the rule and its reporting requirements.

The National Association of REALTORS is actively monitoring developments and has previously provided education and resources to help members understand the rule.

We will continue to keep members informed as more information becomes available. Our goal is to ensure you have clear, timely guidance so you can focus on serving your clients with confidence.

If you have questions, please don’t hesitate to contact our office.