Criminals purchase real estate with illicit funds and channel these funds through an escrow account, leveraging its appearance of third-party control to obscure the true source of money. They then quickly resell the property (“flipping”) at or near market value, converting the proceeds into seemingly legitimate funds tied to a documented sale. Escrow services, widely used in routine real estate transactions, handle large sums and multiple disbursements, which makes them attractive for concealing rapid turnover of illicit capital. By exploiting this structure, offenders layer funds under the pretense of standard property closings, limiting scrutiny from financial institutions and regulators. Once the resale is completed, the laundered proceeds appear to originate from a legitimate property sale rather than criminal activity.
Real Estate Escrow Flip
Real Estate Escrow Flip
Tactics
Real estate escrow flipping converts illicit funds into legitimate sale proceeds, allowing criminals to finalize the integration stage by merging criminal capital with lawful assets under the guise of a legitimate property sale.
Risks
Criminals exploit the inherent vulnerabilities of real estate transactions and escrow processes to quickly flip properties and obscure the origin of funds. The escrow structure, widely trusted as a neutral third party, reduces scrutiny of large deposits, multiple disbursements, and rapid turnover. This allows illicit funds to be layered and integrated under the guise of legitimate real estate sales.
Indicators
Large real estate purchases funded with cash or opaque financing methods, bypassing typical escrow or mortgage mechanisms, indicating an attempt to conceal illicit funding sources.
Rapid secondary sale of real estate property shortly after purchase, indicating a deliberate layering tactic to mask illicit fund origins.
Use of multiple intermediaries, shell companies, or non-traditional third-party agents in real estate transactions, especially during escrow, masking the true identity of buyers or sellers.
Substantial discrepancies between initial real estate purchase price and the subsequent resale amount, deviating from prevailing market data and suggesting manipulation of property values.
Real estate deals spanning multiple jurisdictions or payment channels with incomplete or inconsistent documentation, indicating an effort to obscure the origin of funds.
Frequent real estate acquisitions and sales by a customer with no credible matching income or business activity, indicating possible real estate-based money laundering.
Frequent or unusually large deposits into real estate escrow accounts that exceed typical closing costs or contradict the buyer’s financial profile.
Escrow accounts hosting multiple rapid real estate purchases and sales with minimal intervals, suggesting a strategy to launder funds through quick property flips.
Multiple disbursements from an escrow account to unrelated third parties after property closing, deviating from standard distributions for sellers, taxes, or fees.
Data Sources
- Provides timestamps, amounts, and transaction identifiers for financial inflows and outflows, including deposits into and withdrawals from escrow accounts.
- Assists in detecting irregular or rapidly repeated transactions linked to real estate purchases and flips.
- Contains detailed records of escrow account ownership, balances, and transaction histories.
- Facilitates detection of large or repeated deposits, multiple unexpected payees post-closing, and rapid fund movements indicative of money laundering via real estate flips.
- Aggregates customer identity, financial, and risk profiling details, including declared income and business activity.
- Helps identify customers engaging in frequent real estate flips or high-value transactions through escrow that exceed their known financial profiles.
- Details property ownership transfers, transaction dates, purchase values, and involved parties.
- Highlights rapid property flips, discrepancies in purchase and resale amounts, and the use of escrow services, supporting the detection of layering through quick resale schemes.
- Captures transaction flows between different jurisdictions, currencies, and financial institutions.
- Reveals cross-border elements in real estate purchases and sales, helping trace the origin of funds when flipping properties through escrow.
- Documents business registration details, ownership structures, shareholders, and potential shell entities used in property deals.
- Enables verification of ultimate beneficiaries behind real estate transactions involving escrow accounts, helping expose hidden or suspicious actors.
Mitigations
Apply enhanced due diligence for real estate escrow transactions that display short holding periods, large capital inflows from less transparent sources, or significantly mismatched property valuations. Verify the property's ownership chain, check all beneficial owners, and request proof of legitimate sources for high-value funds or rapid flips to uncover layering attempts.
Collect and verify detailed information on parties involved in real estate purchases and sales, including beneficial owners, declared incomes, and supporting documentation for large deposits. Cross-check the provided data against official property records and external sources to identify frequent or unexplained property flips indicative of layering.
Implement targeted monitoring scenarios focusing on escrow-based real estate deals. Flag multiple rapid sales, sudden property flips, or recurring disbursements to unrelated parties from the same escrow account. Investigate abrupt ownership changes or unusual price movements that deviate from typical real estate market practices.
Assess the AML controls of real estate brokers, escrow agents, or title companies involved. Require formal policies on beneficial ownership checks, property valuation reviews, and transaction oversight. Discontinue or limit partnerships with third parties who fail to maintain adequate safeguards against real estate flipping schemes.
Provide specialized training for loan officers, escrow personnel, and compliance staff on identifying rapid resale transactions, inflated or deflated property prices, and disbursements to numerous third parties. Instruct employees on immediate escalation protocols for questionable real estate escrow activity.
Enforce strict internal controls for escrow accounts used in real estate purchases. Require documented proof of legitimate fund origin, validate property titles and ownership history, and ensure disbursements align with standard closing distributions. Postpone or restrict any release of funds if significant red flags emerge regarding the escrowed property or parties involved.
Use publicly available property records, real estate databases, and valuation tools to validate the claimed purchase and resale prices. Identify large discrepancies between initial and subsequent sale amounts. Confirm short holding periods or unusual buyer-seller relationships that suggest intentional flipping for illicit fund layering.
Continuously update and review customer risk profiles to detect repeated real estate flips, abnormal escalations in property values, or suspicious escrow transactions. Reevaluate the source of funds if a pattern of quick purchase and resale emerges, and escalate the customer's risk designation accordingly.
Instruments
- Criminals purchase properties using illicit funds with the intent to quickly resell ("flip") them through standard real estate channels.
- By channeling these transactions through escrow, the purchase and resale appear as routine closings, concealing the illicit source of the capital.
- Once flipped, the proceeds are documented as coming from a legitimate real estate sale, effectively layering and integrating criminal funds.
- Escrow arrangements in real estate typically function as a form of trust account controlled by a neutral third party.
- Criminals deposit illicit funds into the escrow/trust account during a property purchase, masking the true source by presenting the transaction as a legitimate buyer deposit.
- The trust account’s third-party oversight and legitimate appearance reduce scrutiny, allowing a quick sale flip that reintroduces the funds as proceeds from a documented real estate transaction.
Service & Products
- Criminals channel illicit funds into real estate closings, disguising them as standard payments for property purchases.
- By rapidly reselling (“flipping”) these properties, laundered proceeds appear to come from routine real estate sales rather than criminal activity.
- Escrow accounts hold funds under third-party control, lending legitimacy to large sums moving through real estate deals.
- Criminals exploit the rapid turnover of funds via escrow, making subsequent resale proceeds appear to originate from a legitimate property closing.
Actors
Real estate professionals facilitate property purchases and sales, sometimes unwittingly enabling rapid flips for illicit operators. By coordinating listings, showings, and closings:
- They streamline transactions that can obscure the true source of funds.
- Their routine involvement in real estate procedures lowers suspicion, allowing criminals to complete quick resales through ostensibly normal channels.
Escrow agents function as a neutral party holding funds during real estate closings, acting in a trustee or custodian capacity. Criminals exploit this role by:
- Depositing illicit funds into the escrow account under the guise of standard buyer payments.
- Leveraging the third-party oversight image to reduce scrutiny, then disbursing proceeds after a rapid resale as though they stem from a legitimate transaction.
Illicit operators purchase real estate with criminal proceeds, depositing illicit funds into escrow where they appear as legitimate buyer deposits. They then:
- Arrange a swift resale or “flip,” making the final proceeds appear to come from a documented property sale.
- Exploit the perceived third-party control of escrow accounts to reduce scrutiny and mask the funds’ criminal origin.
References
OECD. (2019). Money Laundering and Terrorist Financing Awareness Handbook for Tax Examiners and Tax Auditors. OECD. www.oecd.org/tax/crime/money-laundering-and-terrorist-financing-awareness-handbook-for-tax-examiners-and-tax-auditors.pdf
ACAMS. (2022). Certified Anti-Money Laundering Specialist study guide (Version 6.44). ACAMS. http://acams.org