FinCEN’s Residential Real Estate Reporting Rule Is Now in Effect: Assessing Compliance Obligations and Associated Risk

Alan Winston Granwell, Of Counsel | Holland & Knight

Alan Winston Granwell is Of Counsel in the Washington, D.C. office of Holland & Knight, where he brings more than five decades of deep experience in international taxation to multinational corporations and globally oriented private clients. Known for his substantive grasp of cross-border tax planning, compliance, controversy and transparency initiatives, Mr. Granwell regularly advises on complex international tax matters that span multiple jurisdictions and regulatory regimes.

• Education & Credentials

Mr. Granwell holds an A.B. from Middlebury College, a J.D. from Boston University School of Law, and two LL.M. degrees—one from Boston University in Taxation and another from New York University School of Law. He is admitted to practice in the District of Columbia, Massachusetts, and New York, and is admitted to several federal courts including the U.S. Tax Court and the U.S. Court of Appeals for the Second Circuit.

• Recognition & Leadership

Mr. Granwell’s peers have consistently recognized his excellence in tax law. He has been listed in The Best Lawyers in America for Tax Law for multiple years and featured in Who’s Who Legal for Corporate Tax. His distinguished career also includes recognition by Washington, D.C.’s Super Lawyers magazine. He is a Fellow of the American College of Tax Counsel, reflecting his professional stature in the field.

• Professional Involvement

An active contributor to the broader tax community, Mr. Granwell speaks frequently at major industry and international tax forums. He has presented at events hosted by the American Bar Association Section of Taxation, the International Bar Association, the International Fiscal Association, and the Society of Trust and Estate Practitioners (STEP). Within STEP, he has served as Chair of the Mid-Atlantic Branch and currently serves as Vice-Chair for Programs while contributing regularly to STEP educational initiatives.

• Experience

Mr. Granwell’s practice encompasses advising on international tax planning, transparency initiatives such as the Corporate Transparency Act, FATCA, and the Common Reporting Standard, and representing clients in complex tax compliance and controversy matters. Early in his career he served as International Tax Counsel and Director of the Office of International Tax Affairs at the U.S. Department of the Treasury, where he advised on legislation, regulatory matters and directed the U.S. tax treaty program. Before joining Holland & Knight, he practiced with major Wall Street law firms and boutique international tax practices.

Bruce Zagaris | Berliner Corcoran & Rowe

Bruce Zagaris is a partner at Berliner Corcoran & Rowe LLP in Washington, D.C., concentrating on international regulatory enforcement, cross-border investigations, and international tax controversy. With decades of experience advising individuals, corporations, and sovereign governments, he is widely recognized for his work at the intersection of international tax, white collar defense, extradition, anti-money-laundering compliance, and transnational evidence gathering. His practice focuses on navigating complex, multi-jurisdictional legal frameworks and high-stakes enforcement matters.

• Education & Credentials

Mr. Zagaris earned his Bachelor of Arts, Juris Doctor, and LL.M. in Taxation from George Washington University. He further expanded his international legal training by obtaining additional LL.M. degrees from Stockholm University in Sweden and the Free University of Brussels. He is admitted to practice in the District of Columbia and is fluent in Spanish and Portuguese, with a working knowledge of French—skills that support his extensive cross-border practice.

• Recognition & Leadership

Throughout his career, Mr. Zagaris has received sustained peer recognition for his work in international law and enforcement. He has been selected to Super Lawyers in Washington, D.C., for multiple consecutive years through 2023. His leadership roles include serving as Chair of the American Bar Association’s International Tax Committee and Chair of the ABA Committee on International Criminal Law, as well as serving on the ABA Criminal Justice Section Council. He has also served as President of the Washington Foreign Law Society, reflecting his longstanding leadership within the international legal community.

• Professional Involvement

Mr. Zagaris is the founder and editor of the International Enforcement Law Reporter, a monthly publication he has led since 1985 covering global enforcement developments. He has served in leadership roles with the American Society of International Law, including on its Executive Committee and the Board of International Legal Materials, and currently holds a leadership position within its Cultural Heritage and the Arts Interest Group. He is also affiliated with the International Penal Law Association and frequently speaks on international tax enforcement and cross-border criminal matters.

• Experience

Mr. Zagaris has more than four decades of experience advising on international tax controversy, voluntary disclosures, cross-border investigations, and regulatory enforcement matters. He has represented foreign governments in negotiating tax treaties and financial services agreements and has served as a consultant and expert witness in complex criminal cases. His practice regularly involves extradition, international evidence gathering, anti-money-laundering compliance, and asset recovery matters spanning multiple jurisdictions.

Peter Hardy, Partner | Holland & Knight

Peter Hardy is a seasoned white-collar defense attorney and former federal prosecutor who represents corporations and individuals in complex criminal, civil, and regulatory matters nationwide. Based in Holland & Knight’s Philadelphia office, he focuses his practice on white-collar criminal defense, internal investigations, anti-money laundering (AML) and Bank Secrecy Act (BSA) compliance, tax controversy, and related financial enforcement matters. Drawing on more than a decade of government experience, he provides strategic, practical counsel in high-stakes investigations and litigation involving financial institutions, businesses, and executives.

• Education & Credentials

Peter earned his Juris Doctor, cum laude, from the University of Michigan Law School and holds a Bachelor of Arts in Philosophy and Psychology, summa cum laude, from the University of Michigan. He is admitted to practice in Pennsylvania and the District of Columbia, as well as before multiple federal courts, including the U.S. Tax Court; the U.S. District Courts for the Eastern Districts of Pennsylvania and Michigan and the Middle District of Pennsylvania; and the U.S. Courts of Appeals for the Third and Fourth Circuits.

• Recognition & Leadership

Peter’s professional excellence has been widely recognized within the legal community. He has been ranked by Chambers USA as a leading attorney in Litigation: White-Collar Crime & Government Investigations and has been recognized in The Best Lawyers in America for his work in Tax Law, White-Collar Criminal Defense, and Corporate Compliance. He has also been honored by The Legal 500 USA for dispute resolution and corporate investigations and named a Top Author in White-Collar Defense by the JD Supra Readers’ Choice Awards. During his service with the U.S. Department of Justice, he received the Outstanding Attorney Award from the DOJ Tax Division in recognition of his distinguished public service.

• Professional Involvement

Peter is deeply engaged in professional and civic leadership. He serves as Co-Chair of the Practising Law Institute’s Annual Anti-Money Laundering Program and is a Fellow of the American College of Tax Counsel. He is an active member of the American Bar Association’s Section of Taxation and the Federal Bar Association’s Eastern District of Pennsylvania Federal Criminal Law Committee. In addition to his professional engagement, he contributes to his community through board service, including as Vice-President of the Board of Esperanza Immigration Legal Services and as an Honorary Board Member of Rebuilding Together Philadelphia.

• Experience

Before joining Holland & Knight, Peter served as an Assistant U.S. Attorney in Philadelphia and as a trial attorney in the U.S. Department of Justice’s Tax Division in Washington, D.C., where he prosecuted criminal tax and financial crime cases in federal courts across the country. In private practice, he founded and led anti-money laundering and tax controversy teams, further solidifying his reputation as a national authority in financial enforcement defense. At Holland & Knight, he defends clients in white-collar criminal matters and internal investigations, advises on BSA/AML compliance, and represents clients in civil and criminal tax controversies. He is also the author of Criminal Tax, Money Laundering, and Bank Secrecy Act Litigation, a widely regarded treatise addressing the defense of complex financial crime cases.

Michael C. Titens, Partner | Holland & Knight

Michael C. Titens is a distinguished corporate attorney and partner based in the Dallas office of Holland & Knight LLP. With decades of experience advising domestic and international clients, he is widely respected for his strategic counsel in complex mergers and acquisitions, joint ventures, private equity matters, and cross-border investment transactions. Mr. Titens combines deep legal expertise with a pragmatic approach to help clients navigate sophisticated business challenges and achieve their strategic objectives.

• Education & Credentials

Mr. Titens earned his Juris Doctor, cum laude, from Harvard Law School and his Bachelor of Arts, magna cum laude, from Harvard University. These academic achievements reflect his early commitment to legal excellence and provide the foundation for his highly analytical and effective approach to corporate law. He has been admitted to practice in the State of Texas since 1986, underscoring his long-standing professional presence in the region.

• Recognition & Leadership

Throughout his career, Mr. Titens has received extensive recognition from peers and industry observers. He has been consistently honored in The Best Lawyers in America® guide for Corporate Law from 2013 through 2026, a testament to his enduring reputation for legal excellence. Additionally, he has been selected multiple times as a Texas Super Lawyers honoree in the areas of Mergers & Acquisitions, Securities & Corporate Finance, and Business/Corporate law, illustrating sustained professional achievement. Mr. Titens’s leadership is further reflected in local accolades such as inclusion in D Magazine’s Best Lawyers in Dallas for General Corporate Law.

• Professional Involvement

Mr. Titens is actively engaged in professional and community organizations that extend his leadership beyond the courtroom. He serves on the Board of Directors for Child Find of America, Inc., demonstrating long-term commitment to child advocacy and community service. He also holds a position on the Board of Trustees for TITAS/Dance Unbound, reflecting his support for cultural and artistic endeavors. Throughout his career, he has participated in numerous committees and international business groups, including roles with the Greater Dallas Chamber of Commerce Americas Task Force and the U.S.–Mexico Chamber of Commerce International Resource Committee, underscoring his involvement in fostering cross-border commerce and professional collaboration.

• Experience

With a career spanning nearly four decades, Mr. Titens’s experience encompasses a broad array of high-stakes corporate transactions and strategic legal counsel. He represents U.S. and international clients in structuring, negotiating, and implementing complex mergers and acquisitions, joint ventures, and private equity transactions. His practice also includes advising private equity funds and portfolio companies in formation, financing, and strategic growth matters. Mr. Titens has particular expertise representing Mexican and other international clients, including having served as a resident attorney in the firm’s Monterrey, Mexico office in the 1990s, which enhances his global perspective and bilingual capabilities. He also has a substantive background in cybersecurity and data privacy issues, having previously co-chaired his firm’s Cybersecurity and Data Privacy Group. Through his career, Mr. Titens has guided clients across industries—such as technology, energy, and services—through transformational business and investment deals with clarity and strategic focus.

I. Post-Implementation Reality: What’s Changed & Early Compliance Challenges | 1:00pm – 1:15pm

A practical look at how the Rule has been functioning since March 1, 2026, including workflow disruptions, intake slowdowns, and the real-world friction attorneys are encountering in the first phase of reporting.

II. Determining Reportability in Complex Transactions | 1:15pm – 1:30pm

How to analyze gray-area deals, layered entity purchases, trust structures, and nontraditional transfers to confidently determine when a filing is required—and when it’s not.

III. Filing Responsibility, Beneficial Ownership & Reasonable Reliance | 1:30pm – 2:00pm

Who must file, how designation agreements work, how to manage disputes among closing parties, and how to collect and document beneficial ownership information while properly relying on client-provided data.

Break | 2:00pm – 2:10pm

IV. Malpractice Exposure, Penalties & Enforcement Risk | 2:10pm – 2:40pm

Where attorneys face professional liability if a report is missed or inaccurate, what civil and criminal penalties apply, recordkeeping obligations, and where regulators are most likely to focus enforcement.