This report reviews 25 cases derived from media articles, indictments and civil complaints, involving illicit or highly suspicious funds entering the U.S. commercial real estate market in the past twenty years. It finds at least $2.6 billion of such investments, originating in 14 countries and reaching commercial properties in 22 U.S. states. The properties purchased are just as diverse, from hotels and office buildings to store fronts, industrial sites and even a horse training facility. Politically Exposed Persons or oligarchs, who typically have close ties to political power, feature in 14 of the 25 cases reviewed.
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