By Thomas Delaney, Alex Lakatos, David Beam and Matthew Bisanz (November 29, 2018, 2:47 PM EST) -- A perfect storm for anti-money laundering risk can arise from the use of legal entities to conceal ownership, the limited application of AML requirements to real estate transactions, and the misuse of virtual currency to launder money. For example, (a) the Financial Crimes Enforcement Network has explained that "[t]he misuse of shell companies to launder money is a systemic concern for law enforcement and regulatory agencies, but it is of particular concern in the 'all-cash' segment of the real estate market, which currently has fewer AML protections";[1] (b) the Financial Action Task Force has stated that "the [U.S.] regulatory framework has some significant gaps," including "minimal coverage" of certain "institutions and businesses," such as real estate agents, lawyers and "trust and company service providers";[2] and (c) FinCEN has identified that "virtual currency has the potential to be exploited for money laundering and other illicit finance."[3]...