Alert April 05, 2011

FinCEN Issues Advisory Concerning Reporting Potential Instances of Commercial Real Estate Fraud

The Financial Crisis Enforcement Network (“FinCEN”) issued an advisory (the “Advisory”) to alert financial institutions (“FIs”) to ways in which they can better assist law enforcement agencies when the FIs file Suspicious Activity Reports (“SARs”) concerning potential incidents of commercial real estate fraud.  The Advisory provides examples of common types of commercial real estate fraud schemes and suggests that FIs use the key term “CREF” when reporting incidents of commercial real estate fraud on a SAR.