United States: District Court Vacates Reporting Rules for Cash

In brief

On March 19, 2026, the United States District Court for the Eastern District of Texas in the case Flowers Title Companies, LLC v. Bessent et al. (“Flowers Title”) vacated Financial Crimes Enforcement Network’s (“FinCEN”) Anti‑Money Laundering Regulations for Residential Real Estate Transfers (“Final Rule”). The case held that the Final Rule exceeded FinCEN’s statutory authority under the Bank Secrecy Act (BSA) and therefore violated the Administrative Procedure Act (APA).

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