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27 Fordham J. Corp. & Fin. L. 193 (2022)
Peeking into the House of Cards: Money Laundering, Luxury Real Estate, and the Necessity of Data Verification for the Corporate Transparency Act's Beneficial Ownership Registry

handle is hein.journals/fjcf27 and id is 199 raw text is: PEEKING INTO THE HOUSE OF CARDS: MONEY
LAUNDERING, LUXURY REAL ESTATE, AND THE
NECESSITY OF DATA VERIFICATION FOR THE
CORPORATE TRANSPARENCY ACT'S
BENEFICIAL OWNERSHIP REGISTRY
S. Alexandra Bieler*
His was a scheme for the twenty-first century, a truly global endeavor
that produced nothing  a shift of cash from a poorly controlled state
fund in the developing world, diverting it into the opaque corners of
an underpoliced financial system that's all but broken.'
ABSTRACT
It is estimated that $800 billion to $2 trillion are laundered globally
every year, funding the schemes of bad actors and terrorists alike.
These astronomical sums are moved around the world without
detection; this is in large part due to the ease with which anonymous
shell companies, typically limited liability companies (LLCs), can be
created, particularly in the United States. America is one of the most
egregious enablers of this practice because most states require little to
no information about the person ultimately controlling the entity,
known as the beneficial owner. Working through an LLC, bad
actors often turn to America's luxury real estate market that enables
the cleansing of millions of dollars of dirty money quickly and without
a  trace. Considering  this vulnerability, the  U.S. Treasury
Department's Financial Crimes Enforcement Network (FinCEN)
began to track the beneficial owners behind certain all-cash real estate
purchases made by entities and found that a third of buyers had also
been subjects of a previous suspicious activity report.
* J.D. Candidate, Fordham University School of Law, 2022. Thank you to the Fordham
Journal of Corporate & Financial Law for its outstanding edits and continued support,
both as an author and an editor. I would also like to thank Professor Martin Gelter for his
guidance. Finally, I cannot express how thankful I am for my family and friends for
discussing ideas, reading drafts, and keeping me sane.
1.  TOM WRIGHT & BRADLEY HOPE, BILLION DOLLAR WHALE 85 (2019).
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