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26 U. Miami Bus. L. Rev. 159 (2017-2018)
Floating on Sea of Funny Money: An Analysis of Money Laundering through Miami Real Estate and the Federal Government's Attempt to Stop It

handle is hein.journals/umblr26 and id is 165 raw text is: 

Floating on a Sea of Funny Money: An

Analysis of Money Laundering Through

Miami Real Estate and the Federal

Government's Attempt to Stop it

                        Gary McPherson*

    Miami is experiencing a money laundering controversy the likes
    of which have not been seen since the Cocaine Cowboys era of
    1980's Miami. Condominiums and other mega developments are
    popping up at an unprecedented pace, immediately after the
    housing market crash that caused the Great Recession. Adding to
    this questionable boom in development is the fact that the vast
    majority of Miami's population cannot afford to live in places like
    these. So, the question presented is who is fueling this explosion
    in development? Criminals, that's who. Federal agents believe
    criminals are buying coveted Miami real estate through shell
    companies to launder their ill-gotten money.

    In response to this crisis, the Department of the Treasury's
    Financial Crimes Enforcement  Network  (FinCEN)  issued a
    Geographic Targeting Order (GTO)  that requires Miami title
    insurers to report information about the identities of those hiding
    behind shell companies to buy real estate in cash purchases.
    Through the order, FinCEN aims to gain information about and
    deter potential money launderers. The GTO   places Miami
    squarely in the cross-hairs of FinCEN's anti-money laundering
    regime. However, there is a problem: the GTO will not actually
    prevent money laundering. There are fundamental issues with the
    GTO:  it is underinclusive and riddled with loopholes and

    J.D./LL.M in Real Property Development Candidate, University of Miami School of
Law; Articles & Comments Editor, Volume 26, University of Miami Business Law
Review. Thank you to all who helped me along the way. Your time, effort, and support
were greatly appreciated.


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