Escrow & Title
In Arizona, a title company or escrow agent who suspects money laundering in a real estate transaction should:
AClose the transaction and notify the buyer only
BFile a Suspicious Activity Report (SAR) with FinCEN (Financial Crimes Enforcement Network) and follow Bank Secrecy Act obligations✓ Correct
CContact the ADRE immediately
DRefuse to close without explanation
Explanation
Title companies and escrow agents may have Bank Secrecy Act obligations, including filing SARs with FinCEN when transactions have indicators of money laundering or other financial crimes. FinCEN has expanded real estate reporting requirements.
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