Laundering Illegal Money? There's Ultraluxury New York Real Estate For That

Tyler Durden's picture

For decades, if one wanted to launder a few million (or billion) without paying taxes and attracting undue government attention, the proper venue were bank accounts in Geneva, Zurich or Bern. However, following recent events when courtesy of Barack Obama's tax "transparency" (if nowhere else) initiative, Swiss bank secrecy no longer exists, the world's uber-wealthy were stuck with a quandary: "where do we park our trillions in illicit cash without attracting the attention of tax and government authorities?"

Two years ago we revealed the answer, when we wrote "This is why the NAR will never be prosecuted for facilitating money laundering":

... a foreigner who may or may not have engaged in massive criminal activity and/or dealt with Iran, Afghanistan, or any other bogeyman du jour at some point in their past, and is using US real estate merely as a money-laundering front perhaps? Sadly, we will never know. Why? As explained before, it is all thanks to the National Association of Realtors - those wonderful people who bring you the existing home sales update every month (with a documented upward bias every single time) - which just so happens is the only organization that actively lobbied for and received an exemption from AML regulation compliance. In other words, unlike HSBC, the NAR is untouchable, even if it were to sell a triplex to Ahmedinejad on West 57th street.


As a reminder, here is where the NAR stands on the issue of its most generous clients possibly being some of the worst criminal known to man, courtesy of Elanus Capital:

Many of you reading this will undoubtedly have spent time in an international bank and been forced to sit through countless hours of “know your client” and AML training. Fascinating to note that the National Association of Realtors lobbied for and received a waiver from such regulation. That’s right, realtors actually went to the U.S. government and said: we want to be able to help foreign business oligarchs and other nefarious business people launder money through the real estate markets of the United States – and prevailed.


Here's their official position:


"NAR supports continued efforts to combat money laundering and the financing of terrorism through the regulation of entities using a risk-based analysis. Any risk-based assessment would likely find very little risk of money laundering involving real estate agents or brokers. Regulations that would require real estate agents and brokers to adopt anti-money laundering programs may prove to be burdensome and unnecessary given the existing ML/TF regulations that already apply to United States financial institutions."


Hat’s off to the NAR – that is some serious doublespeak. My translation: We’ll support you as long as we don’t have to support you.

If after skimming the above, readers are still confused what the reason is for the luxury segment of the US housing market continuing to rise in price even as all other segments of the quadruplicate US housing market as explained here languish, we suggest rereading it as many times as necessary.

Indeed, the scheme was all the more attractive to Obama because in one fell swoop, the US president crushed Switzerland as the venue to park hot capital, and instead gave a green light to "deposit" said illegal funds in US ultra-luxury real estate, in the process pushing up real estate prices, if only at the high end, much higher, and giving the population the false impression that the housing market has not only stabilized (it hasn't) but is improving. Case in point: the latest just released NAR pending home sales data, about which even the NAR's always cheerful Larry Yun had the following caveat:

“The flourishing stock market the last few years has propelled sales in the higher price brackets, while sales for homes under $250,000 are 10 percent behind last year’s pace.... Solid income growth and a slight easing in underwriting standards are needed to encourage first-time buyer participation, especially as renting becomes less affordable.”

Odd how the NAR had nothing to say about foreigners abusing the NAR's exemption from anti-money laundering provisions. Which, incidentally, is the only reason why there is still any bid in US housing, which as we have shown before, is entirely at the ultra high end.


Today, we can finally end any debate on the topic of just where the world's illegal money comes to roost. The answer: ultra-luxury real estate, primarily in New York, courtesy of a report in New York magazine that catches up with what we first said in the summer of 2012, and which is titled, appropriately enough: "Stash Pad."

Below are some excerpts:

Extreme wealth demands extremely elaborate wealth management, and anyone who has a few million in spare cash will probably already have an entrée to the cloistered world of private banking. An anonymous high-net-worth client of Credit Suisse, who spoke to U.S. Senate investigators after taking advantage of an amnesty for tax cheats, described the process by which he would manage his funds when visiting Zurich. A remote-controlled elevator would take him to a bare meeting room where he and his private banker would discuss his money; all printed account statements would be destroyed after the visit.


The theatrical secrecy is designed to build personal trust between such bankers and their clients, which is especially vital when the goal of the transactions is to conceal assets from the prying eyes of rivals, vengeful spouses, or tax collectors. Moving the money itself is a relatively simple matter: A wire or a suitcase can convey cash from China to Singapore, or from Russia to an EU member state like Latvia, and once the funds have made it to a “white list” country, they can usually move onward without triggering alarms. Concealing the true ownership of a property or a bank account is trickier. That’s where the private bankers, wealth advisers, and lawyers earn their exorbitant fees.


Behind a New York City deed, there may be a Delaware LLC, which may be managed by a shell company in the British Virgin Islands, which may be owned by a trust in the Isle of Man, which may have a bank account in Liechtenstein managed by the private banker in Geneva. The true owner behind the structure might be known only to the banker. “It will be in some file, but not necessarily a computer file,” says Markus Meinzer, a senior analyst at the nonprofit Tax Justice Network. “It could be a black book.” If an investor wants to sell the property, he doesn’t have to transfer the deed—an act that would create a public paper trail. He can just shift ownership of the holding company.


Recently, scrutiny from the United States has punctured some of the traditional secrecy of Swiss banks. But that has just pushed clients to boutique advisory firms, often run by the same personnel. “Banks like working with those firms,” Meinzer says, “because they are then legally in the clear, without the risk of going to prison.” As international blacklisting has pushed some offshore locales toward greater legal compliance, new havens have arisen. New Zealand trusts offer similar secrecy to those of the Caymans, without the stigma.


It’s a sophisticated, well-oiled system that rarely requires crude subterfuge. Though U.S. authorities track all transfers over $10,000, a wire into a real-estate lawyer’s escrow account should look perfectly routine. “A lot of times, I don’t even know where my clients are from,” says the lawyer Bruce Cohen. “But I know that certain countries are very careful about the money that leaves their country.”


There is nothing illegal—at least from the destination nation’s perspective—about sending money from an anonymous offshore bank account to purchase property in America. On the contrary, it’s an everyday occurrence. That is precisely why experts say that property investment is a favored route for money laundering, a crime that depends on the outward appearance of legitimacy. The laundering process typically happens in stages: Illegal cash enters the world financial system somewhere and is funneled into a maze of accounts and shell companies, a process called “layering.” Finally, at the other end, funds are integrated into a seemingly respectable investment—like a luxury condo.


Secretive corporate structuring is a key element in the process. Earlier this year, an international team led by Shima Baradaran, a law professor at the University of Utah, published an ingenious study of its mechanics. The academics sent emails to more than 7,000 firms around the world that offer incorporation services, posing as a variety of characters, like a politically connected Uzbek or a Lebanese representative of an Islamic charity. “We purposely made it as shady as possible,” Baradaran says.


The experiment’s results confounded conventional presumptions. It turned out that offshore locales like the Caymans were the most stringent about complying with international anti-money-laundering standards. It was easier to set up an untraceable shell company in the U.S. than in any country other than Kenya. The study found firms in business-friendly states like Delaware and Nevada were particularly “abysmal.”


No federal authority, not even the IRS, keeps track of the actual “beneficial” owners behind LLCs, and the more lenient states don’t even require much record-keeping by the firms that handle incorporation. Many of the service providers Baradaran’s team approached asked for no identity documentation and were willing to set up LLCs in even the most suspicious scenarios. Most surprisingly, Baradaran found that the suggestion of foreign corruption actually increased the likelihood that a provider would agree to do business. “It’s really a race to the bottom,” Baradaran says.


Lawyers, brokers, and other service providers fall into a category that money-laundering experts refer to as “gatekeepers.” An international organization formed to combat such financial crime has called for gatekeepers to be required to report suspicious activity, and some nations, like Great Britain, have placed disclosure requirements on attorneys. But no such regulation exists in the United States, and while financial institutions are tightly monitored under the 2001 USA Patriot Act, parties to property transactions have been given a specific exemption. “It’s a big hole,” says Louise I. Shelley, director of the Terrorism, Transnational Crime and Corruption Center at George Mason University.


In 2010, Senator Carl Levin released the results of an investigation into the role of U.S. property in foreign corruption, highlighting cases like that of the son of the dictator of Equatorial Guinea, who bought a $30 million Malibu mansion. New York real estate often figures in such scandals. Ukrainian politician Yulia Tymoshenko has filed a civil lawsuit claiming a crony of the country’s ousted president moved tainted money into New York development projects, while her opponents claim, in turn, that she laundered money through the city’s real estate. In 2012, federal prosecutors seized a Trump Park Avenue apartment from the son of a Philippine general who had been convicted of taking bribes. A $1.6 million condo in the Onyx Chelsea, belonging to a former Taiwanese prime minister, was seized after it was tied to a corruption scandal.


Such cases are rare and laborious, however. “You have to prove the nexus between the corruption and the property itself,” says Jaikumar Ramaswamy, chief of the Justice Department’s Asset Forfeiture and Money Laundering division. “Sometimes judges are skeptical: ‘Why are we are going after some foreign guy who did something in a foreign country?’ ”

That's funny: because why is Obama and Eric Holder going after BNP, Barclays and HSBC for precisely the same reason? The answer is simple: America is desperate for New York to become the money-laundering capital of the New Normal: it desperately needs the offshore money to keep coming in, keeping prices as high as possible. In fact, this has already happened, and furthermore it has the full blessing of everyone in charge.

As for the bottom line:

The best—though still fuzzy—global estimates say as much as $1.5 trillion in criminal proceeds is laundered each year. The United Nations figures that as little as one-fifth of one percent of that is ever recovered. Levin has proposed legislation to extend the Patriot Act’s regulations to real-estate closings and to require disclosure from LLCs, but the bill has gone nowhere. Real-estate attorneys say such rules would violate their legal privilege, and brokers insist the marketplace already provides an incentive to keep transactions clean. “No building wants to have people who have made illegal money,” says Mark Reznik, a broker at A&I Broadway Realty, a firm that primarily serves Russian-speakers. Reznik says he provides a “prescreening” service for developers. “They want to have some kind of filter,” he says. “Like somebody said, Karl Marx or whatever, if the capitalist is going to see a triple return, he’s going to close his eyes. But we are trying not to deal with scumbags.”

Karl Marx did not say that but all those Americans who make money legally and who are trying to buy a place in New York, or any other US city targeted by money laundering foreign oligarchs, and who say "I am priced out of the market by criminals allowed to bid up real estate to the moon", well... sorry, you are out of luck. Thank America's corruption which starts at the bottom and stretches to the very top.

Read the full New York Mag article here.

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Stoploss's picture

NY makes offshore accounts look like kindergarten piggy banks..

Greenskeeper_Carl's picture

Don't worry, I'm sure their new socialist mayor will get right on that...

DoChenRollingBearing's picture

Indeed.  But, it was still a very interesting article.  

H/T to the Tylers for running this one.  

Maybe the takeaway lesson is once Americans get their money out of the USA OK, then it will find a nice welcome home there in the Big Apple.

ParkAveFlasher's picture

A large proportion of commercial activity is the elaboration of old money turning itself over.  Why do people think that things are changing?  Just because your awareness of the world evolves, doesn't mean that the world is changing.  You are just noticing the aroma.

PT's picture

I believe that the amount of money to be laundered would swamp the amount of viable real estate available and so first in is best dressed and sooner or later this game will stop working.  But the truth is, I really don't know.  Has anyone run those numbers?  Is real-estate money laundering long-term sustainable?

V in PA's picture

Logged in just to upvote. Well said.

newdoobie's picture

Why do people think things are changing?... I'm stealing that line!

RaceToTheBottom's picture

Another circular aspect of finance.....

halfasleep's picture

i look forward to squatting a nice pad when shtf.

Emergency Ward's picture

"We movin' on up, to the Eastside,

to a deeeluxe apartment in the skyyy!"


The Jeffersons have just been priced out of the market.

knukles's picture

There's an EBT App for that.

Emergency Ward's picture

Gk crl -- you must have meant that the new mayor will get right "in" on that...

astoriajoe's picture

Cyrpus had a bunch of somewhat dubious, foreign money in their banks too, if I recall. Maybe that was a different country.

Theta_Burn's picture

Apparently there is a method to the madness.

When it comes to protecting the status-hoe, America is truly exceptional...

prains's picture

....anything for a dollar, i mean a.n.y.t.h.i.n.g

Temporalist's picture

You say "corruption" and I say "recovery".

Ignatius's picture

"Only the little people pay taxes."

Thanks for the God send clarification, Leona.

NotApplicable's picture

Meanwhile, any little people wanting a mortgage have to produce a paper trail for every fucking dime that passes through their hands, so that the "lender" doesn't get beat up for going afoul of the Anti-Money Laundering Law.

Wait, you paid rent in cash!?!?!! You must be a criminal, so NO LOAN FOR YOU.

I'm going to assume that the sub-100k homes are in such bad shape that none of them qualify for "loans"  from Uncle Sugar.

Next up, urban blight and its good friend eminent domain.

RaiZH's picture

I find it amazing that people know very well that the uber rich are even paying $100+ million for penthouses, and often keep them empty.

Yet can not see what is really happening and realise they are being robbed in broad daylight.
The monetary and physical planes are severely out of place, most of these guys are just close to the printing press.
When people realise this imbalance, you will have your sh*t storm. 

All fiat "money" is illegal in my books. 

OpenThePodBayDoorHAL's picture

And um no there's "no inflation', uh-huh, condos and homes in London should be $150M uh-huh that's normal. Jim Grant is right, the definition of "inflation" should not be "too much money chasing too few goods and services" should just be "too much money". 

RaceToTheBottom's picture

That is not a very nice or ethical way of acting...


Quick, lets cancel some Obama cards cause those poor people are buying pop with them and dumping the liquid and using the cans to buy cigarettes.  That will solve it....

NoDebt's picture

Almost done.

Conversion back to Feudalism is within their grasp.  They can see it, they can smell it, they can taste it.  As it was, of course, intended to be all along.

Thank God this fiction of democracy, rule of law and equal protection is about to be snuffed out for good.  What a DISASTER that whole experiment was.  Good riddance.  You can blame it on the US Constitution but I actually prefer to blame the Brits because they got that whole thing rolling with the Magna Carta.  Well, at least we won't have to worry about that stuff any more.  Almost done.

Reaper's picture

How much will Cuomo, NY AG Schneiderman and Holder charge for protection? Laundering isn't free.

Argos's picture

I imagine buying off a politician is much cheaper than a banker.

ParkAveFlasher's picture

NYC is a huge money laundering conduit, why is this surprising anyone?

ptoemmes's picture

Maybe instead of becoming first time home buyers, people should aspire to become first time money launderers by becoming, you know, criminals.

Crime may become, if not already, a booming "job" market.

Oh wait...

RaceToTheBottom's picture

Financial crime is the latest FED inspired bubble

oklaboy's picture

gives the Fed something to seize when the direction the wind blows changes..... 

TheFreeLance's picture

If your county is of the right size -- 500K to 1mil. residents -- and reasonbly wealthy, you can amuse yourself by checking online property records for all kinds shady dealing. Gradually you'll find that a handful of players are unnaturally connected to local and state lawmakers and all sorts of money and notes change hands without any discernible business purpose. Two fun tricks are selling property to pols at below market rates for a quick flip of $10K-$50K and mysterious promissory notes that cut in third parties for no obvious reason. I once found a law firm that regularly added a state house member to several deals a year, creating and destroying notes at a dizzying pace, the upshot being about a $50K annual float for the guy.

Jack Burton's picture

High end real estate in New York, London, LA and other western safge havens are on fire. Itäs a double win for the foreign rich or the foreign crooks. Not only do you get the real estate, you get it to live in should you need to bail out of your home country when social order or law enforcement become a problem. NY is really on fire! Nothing being built is too luxurious or expensive.

It is funny to watch these real estate shows and see how much money can be poured into an aprtment or house. Like an apartment in New York with 8 bathrooms and a swimming pool!

p00k1e's picture

Meanwhile, if you or I "get caught" with $10,000.... well, say good bye to your cash. 

Herdee's picture

Add in a good portion of real estate on the U.S. west coast.Canada has actually been the so-called money laundering capital of North America.It has been done by corrupt Government Officials designing and passing legislation to bring in vast numbers of immigrants based on how much money they must have along with what they must purchase and how long they must stay in order to get their pensions.The schemes were put in place to prop up Canadian Banks after Prime Minister Harper and his Conservative cronies bailed out the Banks in Toronto and took hundreds of billions of bad mortgages off of their books and dumped them on CMHC (Canada Mortgage and Housing Corporation)who is also acting as a public insurance provider.Funny that CMHC was originally intended only to provide loans for low income housing so that poor people could get their own place to live.Even the IMF has warned everyone about Canada's danger.One of Harper's own Cabinet Members even quit and went to work as a top member in CIBC.Harper is a National disgrace and a U.S. puppet stooge along with his former Justice Minister Vic Toews.Vic while in Office impregnated an 18 year old girl.This guy's in his 60's and was rewarded with a position on the Manitoba Bench as a Judge.His own family says he's a pervert.Shows the extent of corruption in Canada throughout the legal system and in Politics.You don't need any morals to be a Judge.Canada has seen a sharp increase in real estate prices mostly from corrupt Chinese Communist Members fleeing Red China on the graft clampdown.A lot of corrupt money also flows in from India and England too.

Handful of Dust's picture

Cali, Florida and NYC .... Looters' Money Laundering Paradises!

Jack Sheet's picture

The costs must be a bitch. Taxes, maintenance, service charges, repairs, utilities, hostesses... the list is endless

The Carbonator's picture

As long as this benefits the liberal socialists in New York City this will go on and on.


Through all the scandals, Lehman, sub-prime loans, bailouts, manipulation fraud abuse etc.  Only 1 went to jail, Bernie.  His crime was that he feasted on the elites in Manhattan.  The rest was just par for the bankster course.

q99x2's picture

When you have the likes of scumbuckets such as Obama, Graham and Cheney saying that a bigger false flag than 911 is needed seems like those stash pads come with an associated risk factor.

Blankenstein's picture

The crime syndicate called the NAR needs to be disbanded.  On top of aiding and abetting money launderers and wanting immunity from prosecution, they are a nationwide cartel of price fixers.  Bring on RICO.

DerdyBulls's picture

Oh, come on. I dislike NARLY as much as next guy but the expansion of black markets is a check on and a normal corollary to the expansion of tyranny. Expect to see much more. Screw the Levin gestapo and the horse they rode in on. What are people saying on this string? "Thank you sir may I please have another?" If a foreigner wants to buy my real estate I only want to know what color the money is. This is complicated. How in the hell am I going to really know where it came from anyway, or my frickin attorney for that matter? I’ll put it to legal uses and pay taxes due. I think some panties need un-wading. 

TheFreeLance's picture

You are missing the extent of the scam. How do you KNOW your frickin' attorney is working for YOU?

Banks and law firms are part and parcel of the fix.  Banksters everyone gets, but lawyers are looking to get paid too. Yeah, some are totally ignorant of the plays, ie, incompetent (which is its own set of costs) but no way that most lawyers miss a sideways deal when they see one.

More broadly, you always want a hungry and poor lawyer, ideally young and just out of law school, to do your real estate work. They have yet to be corrupted. Living in DC during the 00s run up, I had an employer-proved retained platinum law firm. Doing a relatively uncomplicated real estate deal with financing, I gave them the paper work. I knew there were great howling frickin errors -- tax credits and references to state-outlawed pre-payment penalties were a couple -- but I was curious. Nothing got flagged by this firm that did a TON of real estate work. It has to be much worse now.

Meanwhile, I cut a $200 check to girl about two years out of school and met with her in a mall food court. She red-flagged those issues and about 10 more. Closing was a hoot with a bunch of nervous laughs and "we'll fix thats" with a couple K kicking back to me from the "good faith" paperwork.

Best of all, I soon heard that the platinum law firm was not pleased I had gotten a 2nd opinion. (How did they know?) I waited awhile and invented a reason to interface with them (something about a fence on an easement IIRC) and after pleasantries of a couple minutes comes, "So, are you a cop of some kind?" I laughed and laughed.

DerdyBulls's picture

I guess I don't know, for certain, that my attorney is working for me. I'm paying him. Beyond that I'm in the dark. Mortgage bankers and brokers around where I live are pretty paranoid. Fraud is always a short-term play. Sooner or later it catches up to them. Business just doesn't have to be done that way. Sad.

DerdyBulls's picture

I guess I don't know, for certain, that my attorney is working for me. I'm paying him. Beyond that I'm in the dark. Mortgage bankers and brokers around where I live are pretty paranoid. Fraud is always a short-term play. Sooner or later it catches up to them. Business just doesn't have to be done that way. Sad.

SmittyinLA's picture

Bullish for municipal bond debt 

Every increase in real estate prices is an increase in bond debt potential, that was the real goal of the bank bailout, to keep the municipal bond debt growing

alexcojones's picture


Bernie Madoff: Major Crime

Screwed The Tribe: Does Major Time

and the son suffered too.

Mark Madoff Suicide: What He Knew - The Daily Beast


ajax's picture



... and for everyone else there's FATCA. "Can't leave home without it."

DrunkenMonkey's picture

Just logged in to say thanks to the Tyler(s) for the incredible quality of the posts today.

overmedicatedundersexed's picture

thanks TD's..shine light in dark areas, gives us all a leg up. if you are in the system with eye's wide shut, you are everyone's fool.