Beginning March 1, a new federal rule will quietly reshape how certain residential real estate transactions are handled across the United States — including here in Puerto Rico. The change comes from the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Treasury responsible for combating financial crimes. The rule targets a specific type of transaction: all-cash purchases made through legal entities such as LLCs, corporations, partnerships, or trusts.
For many buyers in Puerto Rico — particularly in markets like Vieques, San Juan, and Rincón — this will not prohibit purchases, but it will introduce new disclosure requirements that cannot be ignored.
At its core, the rule requires that when a residential property is purchased without financing and the buyer is a legal entity or trust, certain “beneficial ownership” information must be reported. That includes the true individual behind the entity — their name, date of birth, address, taxpayer identification number, and citizenship information. In simple terms, if an LLC buys a home in cash, the government now wants to know who ultimately owns or controls that LLC.
The stated purpose is to reduce money laundering through residential real estate. According to the U.S. Treasury’s 2024 National Money Laundering Risk Assessment, roughly 20 to 30 percent of U.S. real estate transactions are completed in cash. When a lender is not involved, the traditional anti-money-laundering checks that banks perform are bypassed. High-end and second-home markets have long been viewed globally as vehicles for moving or storing capital discreetly. The 2021 Pandora Papers investigation reinforced these concerns, revealing hundreds of U.S.-based trusts holding billions in assets, some connected to allegations of fraud and corruption.
While the intention of the rule is clear, its practical impact will likely fall most heavily on legitimate buyers who use entities for perfectly lawful reasons. In Puerto Rico, it is common for mainland buyers to purchase through an LLC for liability protection. Others use trusts for estate planning. Investors often structure ownership entities to separate personal and property-related risk. None of that changes — but anonymity does.
For most buyers, the new rule will simply mean additional paperwork and coordination during closing. There may be slightly longer timelines if entity documents are incomplete or beneficial ownership details are not organized early. Title companies and settlement agents will need to collect and file the required information. The data is reported to FinCEN, not posted publicly on the MLS, but the era of quiet entity-based all-cash purchases is narrowing.
Will this slow down the Puerto Rico market? Probably not in a meaningful way. Serious buyers who are already compliant with tax and legal obligations will adjust. Disclosure does not prevent ownership; it formalizes transparency. However, buyers who rely heavily on privacy for personal or strategic reasons will need to plan more carefully. The days of forming an LLC the week before closing and assuming that is the end of the conversation are over.
For those considering a cash purchase in Puerto Rico — whether on Vieques or elsewhere — the practical advice is simple: plan early. Decide whether you are purchasing personally or through an entity before you go under contract. Make sure your LLC or trust documents are properly structured. Confirm that beneficial ownership details are accurate and readily available. Work with professionals who understand both local transaction customs and federal compliance requirements.
Real estate in Puerto Rico continues to attract buyers for lifestyle, diversification, and long-term planning. That appeal has not changed. What has changed is the regulatory backdrop. Transparency expectations are increasing nationwide, and Puerto Rico is no exception.
At Paraiso Realty, staying ahead of regulatory shifts is part of protecting our clients’ transactions. The goal is still the same: smooth closings, clean structure, and long-term peace of mind. The island lifestyle should feel simple. The preparation behind it should be thoughtful.
If you are considering an all-cash purchase through an LLC or trust, it is worth having the conversation early — before the contract is signed, not after.
If you are ready to buy a new property in Puerto Rico, click on one of the images below to see if that property is a good fit for you:
