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National Security
Reference:

Threats to the economic security of the Republic of Mari El in the field of countering the legalization (laundering) of proceeds from crime in the market for the sale of real estate

Shemyakina Marina Sergeevna

ORCID: 0000-0003-3515-2680

PhD in Economics

Associate Professor, Department of Accounting, Taxes and Economic Security, Volga State Technological University

424000, Russia, Yoshkar-Ola, Lenin Square, 3

sh.marina.s@gmail.com
Other publications by this author
 

 

DOI:

10.7256/2454-0668.2023.5.43903

EDN:

NONZQF

Received:

25-08-2023


Published:

29-11-2023


Abstract: The subject of the research is the relations that arise in the process of combating the legalization (laundering) of criminal proceeds in the economy. The author substantiates the need to change the current legislation in terms of classifying self-employed persons who provide intermediary services in real estate purchase and sale transactions as persons who are required to register with Rosfinmonitoring and exercise mandatory control over part of the transactions. In the article, on the basis of the algorithm developed by the author, a check was made of the compliance of realtors and real estate agencies of the Republic of Mari El with the legislation in the field of combating the legalization (laundering) of proceeds from crime. Particular attention is paid to recommendations for improving the mechanism of operation of the Domclick service with realtors and real estate agencies.The scientific novelty of the study lies in the identification of real estate purchase and sale transactions through the Domclick service, which are carried out by real estate agencies that are not registered with Rosfinmonitoring and do not exercise mandatory control over transactions, as well as determining the share of transactions in the primary market that are subject to mandatory control using the example Republic of Mari El. The results obtained contain practical recommendations for changing the current legislation, develop theoretical provisions in terms of ensuring the economic security of public legal entities, and also determine the identification of one of the threats to the economic security of the Republic of Mari El: the threat of legalization (laundering) of proceeds from crime in the market sale of real estate.


Keywords:

economic security, threats, AML, legalization of income, money laundering, counteracting money laundering, property market, purchase and sale of real estate, realtor, National security

This article is automatically translated.

Introduction

   In the 2018 Report on the sectoral assessment of the risks of money laundering and terrorist financing using organizations and individual entrepreneurs providing intermediary services in the implementation of real estate purchase and sale transactions, the real estate sector is characterized by an increased level of criminalization [1]. Numerous cases from Russian practice confirm this provision [2,3,4,5], in 2022 alone, 7,500 objects of property [6], including real estate, were seized in favor of the state from persons who committed crimes, mainly of a corruption orientation. The acquisition of such objects is the giving of a legal form to funds obtained by criminal means. In this regard, the relevance of the research topic is beyond doubt.

  The purpose of this study is to develop theoretical provisions in terms of ensuring economic security in the field of countering the legalization (laundering) of proceeds from crime in the real estate purchase and sale market on the example of the Republic of Mari El. To achieve this goal, the following tasks are defined in the work: to verify compliance by realtors and real estate agencies of the Republic of Mari El with legislation in the field of countering the legalization (laundering) of proceeds from crime; identify threats to economic security; make recommendations on expanding the subject composition of persons exercising mandatory control of real estate purchase and sale transactions worth more than 5 million rubles.

     Literature review

    In the foreign literature, the issues of the risks of money laundering and terrorist financing with the use of organizations and individual entrepreneurs providing intermediary services in the implementation of real estate purchase and sale transactions are studied in detail. Most of them reflect the specifics of the legislation of the country under study: Malawi [17], Austria, Germany, Liechtenstein and Switzerland [18], Colombia [19], the United Arab Emirates [20], Italy [21], Malaysia [22], Canada and Great Britain [23]. They are united by one common conclusion: "systems of laws, rules and institutions designed to counter money laundering provide powerful tools to fight corruption" [24].

  During the analysis of publications in journals recommended by the Higher Attestation Commission, more than 150 studies were identified on the keywords "laundering of income", "countering the legalization (laundering) of income", "legalization of income", "FZ 115" and other derivatives of them. However, most of them consider the issues of the activities of the internal affairs bodies to solve crimes, various aspects of the typology of money laundering. Issues related to financial monitoring and the problems of its organization are disclosed in numerous works, since 2006 more than 300 articles on this topic have been published. It should be noted that financial monitoring is considered as a tool for countering threats to economic security [7,8], as a condition for ensuring financial security [9], as a method of control in the management of economic security [10]. At the same time, countering the legalization (laundering) of proceeds from crime is directly, according to some authors, one of the elements of economic security [11,12,13].

  Despite this, there are practically no fundamental studies that would address the issue of income legalization in the Russian real estate purchase and sale market. The exception is a study conducted by Transparency International on compliance by Russian real estate organizations with anti–laundering legislation [14].

   The research methodology is based on general methods of scientific cognition: comparison, collection and study of data, statistical research, synthesis of theoretical and practical material – and is based on the developments of Russian and foreign scientists on the problems of economic security in the field of countering the legalization (laundering) of proceeds from crime.

  Analysis of legislation on registration of organizations and individual entrepreneurs engaged in transactions with cash or other property

    The Decree of the Government of the Russian Federation of 27.01.2014 N 58 (ed. of 10.04.2023) "On approval of the Regulations on registration with the Federal Financial Monitoring Service of organizations engaged in transactions with cash or other property, and individual entrepreneurs in whose field of activity there are no control (supervisory) bodies" defines the accounting rules. According to subclauses d and subclauses d of clause 2, organizations and individual entrepreneurs providing intermediary services in the implementation of real estate purchase and sale transactions are subject to registration with the territorial body of the Federal Financial Monitoring Service in accordance with the place of state registration of the organization and the place of residence of the individual entrepreneur. Registration is carried out no later than the working day preceding the day of the conclusion of the first contract for the provision of relevant services.

   It should be noted that neither the law, nor the government decree, nor the information letters contain a provision that the self-employed who carry out intermediary services in the implementation of real estate purchase and sale transactions are subject to registration. At the same time, due to the introduction of a tax on professional income throughout the country at the end of 2020, these services can also be provided by the self–employed - individuals who do not have the status of an individual entrepreneur. In this regard, it is necessary to amend the current legislation by adding these persons to the number of persons exercising mandatory control.

  Thus, realtors – individual entrepreneurs, as well as real estate agencies, in accordance with current legislation, must:

— register with Rosfinmonitoring;

— develop rules and methodology of internal control;

— appoint a special official;

—receive training in financial monitoring (targeted instruction);

— submit reports to Rosfinmonitoring.

   In accordance with Article 15.27 of the Administrative Code of the Russian Federation "failure to comply with the requirements of legislation on countering the legalization (laundering) of proceeds from crime and the financing of terrorism", persons who do not comply with the legislation may be brought to administrative responsibility in the form of a warning or imposition of an administrative fine on officials in the amount of ten thousand to thirty thousand rubles; on legal entities persons — from fifty thousand to one hundred thousand rubles. Also, criminal liability is provided for violation of the law under Articles 174 and 174.1 of the Criminal Code of the Russian Federation.

    Research results

The check was carried out only for realtors / real estate agencies that conducted more than 1 transaction through the domclick service. In total, there are 281 such registered users operating on the territory of Yoshkar-Ola and Medvedevsky municipal district; on the territory of Zvenigovo -2, on the territory of Volzhsk and Volzhsky municipal district – 34, on the territory of Kozmodemyansk and Kozmodemyansky municipal district – 1. Verification was carried out according to the following algorithm developed by the author: on the domklik website in in the realtors section (Figure 1), a selection was made according to the location criterion, then from the open data on the realtor's personal page, his TIN (or the INN of a real estate agency) was taken and through the official Rosfinmonitoring database – the register of registered sole proprietors and organizations https://portal .fedsfm.ru/check-inn – reconciliation was carried out: whether this organization or individual entrepreneur is registered with Rosfinmonitoring.

Figure 1. The interface of the database that is the basis for the verification.

Source: https://domclick.ru/

 

The category of participants "independent real estate experts" was excluded from the study due to the absence of a prop (TIN) for verification in open sources. This is a category of persons who are not members of existing real estate agencies and are self-employed. The total number of such persons carrying out their activities on the territory of the Republic of Mari El through the domclick service is 13 people (they have conducted 196 transactions over the past 12 months). Most likely, none of them is registered with Rosfinmnitoring due to the absence of a binding direct rule of law.

Due to the fact that the data are open, and the Rosfinmonitoring database is mobile – the agency can register with Rosfinmonitoring at any time, table 1 shows "truncated data":  only by the number of employees with a non-zero indicator of transactions and the total number of transactions on the domclick website for 12 months as of July 20, 2023.

Table 1. Identified real estate agencies that are not registered with Rosfinmonitoring and have not restricted the viewing of information about their activities on the domclick website [1].

No. p / p

The number of employees in the team (with a non-zero indicator of transactions)

The number of transactions on the DomClick portal for 12 months

The results of the check on the rosfinmonitoring website

 

 

1

2

35

The sole proprietor is not registered with Rosfinmonitoring

2

7

151

The sole proprietor is not registered in Rosfinmonitoring

3

9

131

The sole proprietor is not registered in Rosfinmonitoring

4

8

95

The sole proprietor is not registered with Rosfinmonitoring

5

7

51

The sole proprietor is not registered with Rosfinmonitoring

6

5

57

The sole proprietor is not registered with Rosfinmonitoring

7

3

31

The sole proprietor is not registered in Rosfinmonitoring

8

4

23

The sole proprietor is not registered in Rosfinmonitoring

9

7

28

The organization is not registered with Rosfinmonitoring

10

2

27

The sole proprietor is not registered in Rosfinmonitoring 

11

1

2

The sole proprietor is not registered with Rosfinmonitoring

12

2

21

The sole proprietor is not registered with Rosfinmonitoring

13

2

35

The sole proprietor is not registered with Rosfinmonitoring

14

2

18

The organization is not registered with Rosfinmonitoring

15

1

6

The organization is not registered with Rosfinmonitoring

16

2

8

The organization is not registered with Rosfinmonitoring

17

3

44

The sole proprietor is not registered with Rosfinmonitoring

18

3

48

The organization is not registered with Rosfinmonitoring

19

1

24

The sole proprietor is not registered in Rosfinmonitoring

20

2

9

The sole proprietor is not registered in Rosfinmonitoring

21

1

8

The sole proprietor is not registered in Rosfinmonitoring

22

1

15

The sole proprietor is not registered in Rosfinmonitoring

23

1

15

The organization is not registered with Rosfinmonitoring

24

1

14

The sole proprietor is not registered with Rosfinmonitoring

25

2

75

The organization is not registered with Rosfinmonitoring

26

2

9

The sole proprietor is not registered in Rosfinmonitoring

27

1

27

The sole proprietor is not registered in Rosfinmonitoring

Source: compiled by the author on the basis of data analysis of the Domclick service https://domclick.ru / and Rosfinmonitoring databases https://portal .fedsfm.ru/check-inn

8 real estate agencies have restricted access to personal information on the domclick portal, on the official website of these agencies or on their pages on the Vkontakte social network, there is also no information about the TIN and other details of the organization, which served as a restriction in checking their activities for compliance with the law.

Two individual entrepreneurs also limited the information. However, we carried out a search for entrepreneurs' data through the FTS database containing EGRNIP information https://egrul.nalog.ru/index.html . After searching for the INN, a check was carried out on the Rosfinmonitoring website, which showed that the IP data are not registered with Rosfinmonitoring (the number of transactions over the past 12 months is 2 and 12, respectively).

Table 2 shows real estate agencies (LLC and IP) operating in the Republic of Mari El and registered with Rosfinmonitoring.

 Table 2. Real estate agencies (LLC and IP) operating in the Republic of Mari El and registered with Rosfinmonitoring

 

No. p / p

The number of employees in the team (with a non-zero indicator of transactions)

INN

The number of transactions on the DomClick portal for 12 months

1

10

12*********0

96

2

14

52*******9

107

3

18

12*********4

116

4

51

12*********4

484

5

5

12*********0

50

6

21

12*******1

285

7

7

12*********6

29

8

5

12*********3

58

9

5

12*******3

155

10

10

12*********6

145

11

6

12*********9

88

12

9

12*********8

105

13

3

12*******6

41

14

4

12*********3

48

15

2

12*******9

27

16

2

11*********1

51

17

1

12*******0

5

18

7

12*******6

89

19

1

12*********3

3

20

4

12*********5

21

21

2

12*********3

70

22

1

12*********2

234

23

2

12*******3

61

24

1

12*******0

5

25

1

12*********3

25

26

1

12*********0

26

27

1

12*********8

36

28

2

12*********8

48

29

2

12*********1

52

30

7

12*********9

119

31

2

12*******1

70

32

3

12*********0

122

33

4

12*******9

14

34

1

12*********9

9

35

2

12*********5

18

36

1

12*********5

23

 Source: compiled by the author on the basis of data analysis of the Domclick service https://domclick.ru / and Rosfinmonitoring databases https://portal .fedsfm.ru/check-inn 

The analysis of Table 2 shows that the number of realtors in the Republic of Mari El who comply with the "anti–laundering" legislation is 218, and the number of transactions made with their participation on the domclick portal over the past 12 months is 2935. At the same time, 20% of agencies of the Volzhsky municipal district and the city of Volzhsk, as well as 50% of agencies of the Medvedevsky municipal district and the city of Yoshkar-Ola are not registered with Rosfinmonitoring. Due to the large number of transactions (30% of the total number) made by these persons over the past 12 months in the Republic of Mari El when using the Domclick service, a change in the system of registration/re-registration of users is required. The author sees the following solution to this problem: when adding new realtors/realtor agencies to work with the system, the Domclick service should check each of these persons for registration with Rosfinmonitoring, and send a message to already registered users asking them to upload a notification of registration with Rosfinmonitoring to the Domclick system. In case of refusal to provide information, it is necessary to restrict the activities of these persons in the Domclick service. This proposal will reduce the risk of real estate purchase and sale transactions worth more than 5 million rubles without mandatory control.

Conclusions

According to the Territorial Body of the Federal State Statistics Service for the Republic of Mari El, a square meter of housing in the Republic of Mari El in the 1st quarter of 2023 cost an average of 65,498 rubles in the primary market, 63914 rubles in the secondary market [15]. Based on the calculation of the minimum limit of the transaction amount, which must be reported to Rosfinmonitoring in case of doubt, the area of housing under such a transaction should exceed 76.5 square meters. The analysis of the unified information system of housing construction [16] according to the indicator "housing construction quartergraphy" (in terms of new buildings), reflected in Figure 2, allows us to conclude that almost 30% of apartments sold on the primary market fall under this quadrature.  At the same time, such a calculation can be considered minimal, in fact, the indicator is much higher. This conclusion was made by us based on the analysis of the three main developers of the Republic of Mari El: SZ Spektr-m; SZ Kazansky Posad + and Rusagrostroy. These developers account for more than 50% of the square meters of housing sold in the Republic of Mari El, and the price per square meter in most of the objects sold exceeds 75,000 rubles.

Unfortunately, due to the lack of such open data for the secondary housing market, it will not be possible to conduct a study in this aspect.

Figure 2. Distribution of apartments sold in the Republic of Mari El by area, m2

Source: UIS ZhS data as of 07/20/2023 [2]

Summarizing the data presented in the study , the following conclusions can be drawn:

1. 30% of real estate purchase and sale transactions through the Domclick service are carried out by 43% of real estate agencies that are not registered with Rosfinmonitoring and do not exercise control over transactions, which is mandatory in accordance with the legislation.

2. More than 30% of transactions in the primary real estate purchase and sale market are subject to mandatory control.

It should be noted that the 115 FZ establishes the obligation to register only persons providing intermediary services for the purchase and sale of real estate. In the information letter of Rosfinmonitoring dated May 12, 2021 No. 62 "On clarification of certain issues of the application of legislation on countering the legalization (laundering) of proceeds from crime and the financing of terrorism, organizations and individual entrepreneurs providing intermediary services in the implementation of real estate purchase and sale transactions", it is explained that such persons include realtors, real estate agencies, as well as agents between the developer and potential buyers of real estate - individuals. At the same time, the developers themselves are not classified as persons who are obliged to exercise internal control and register with Rosfinmonitoring. It should be noted that the limits on cash transactions are set only for settlements between legal entities and individual entrepreneurs, they do not apply to settlements with individuals. This makes it possible to apply the scheme bypassing the "anti-laundering legislation", when realtors do not participate in the real estate purchase and sale transaction, and settlements are made in cash. In this regard, it is necessary to change the legislation on these points. For example, assigning responsibilities to developers who sell real estate independently, without the involvement of agencies and realtors, to organize internal control in accordance with 115 FZ and mandatory registration with Rosfinmonitoring.

The results obtained contain practical recommendations for changing the current legislation, develop theoretical provisions regarding the economic security of public legal entities and the identification of a scheme for the legalization of criminal proceeds in the real estate market with the participation of developers, and also determine the identification of one of the threats to the economic security of the Republic of Mari El: the threat of legalization (laundering) of proceeds from crime, on the the real estate purchase and sale market.

 

[1] Compiled by the author on the basis of open information on the domclick portal and the official website of Rosfinmonitoring as of July 20, 2023.

[2] 1-room apartments are indicated in green, 2-room apartments in blue, 3–room apartments in gray

References
1. Report on the sectoral risk assessment of money laundering and terrorist financing using organizations and individual entrepreneurs providing intermediary services in real estate purchase and sale transactions. Electronic resource. Retrieved from http://www.fedsfm.ru
2. Electronic resource. Retrieved from https://our.home.rf
3. Electronic resource. Retrieved from https://www.rbc.ru/rbcfreenews/5df73b569a794767a424a954
4. Electronic resource. Retrieved from https://www.rbc.ru/society/08/11/2019/5dc545929a7947ab8070d9e5
5. Electronic resource. Retrieved from https://www.rbc.ru/society/28/07/2020/5f1ff87d9a7947b3a4f04ad1
6. Electronic resource. Retrieved from https://www.rbc.ru/society/01/11/2019/5dbc113a9a7947cc5d311264
7. Electronic resource. Retrieved from https://realty.rbc.ru/news/6411c3d39a7947147e6d659e
8. Danchikov, E.A., & Omelchenko E.Yu. (2019) Financial monitoring as a tool to counter threats to economic security when introducing innovative financial technologies. Law and Digital Economy, 4(06), 5-9.
9. Leshchenko, Yu.G. (2019) Financial monitoring as a mechanism for ensuring the economic security of the Russian Federation. Economic Security, 2(4), 371-384.
10. Proshunin, M.M. (2016) Financial monitoring as a prerequisite for ensuring the financial security of the state. Bulletin of the Peoples' Friendship University of Russia. Series: Legal Sciences, 3, 133-144.
11. Kuznetsova, E.I., Gamonenko S.S. (2015) Financial monitoring as a method of control in the management of economic security. Bulletin of the Moscow University of the Ministry of Internal Affairs of Russia, 1, 185-189.
12. Shchelkanov, A.A., Forgunova A.Yu., Kotina T.A. (2020) Countering the legalization of money laundering as an element of the bank's economic security. Financial Economics, 8, 121-125.
13. Minakov, A.V., & Lapina, S.B. (2021). Financial monitoring in the system of ensuring the economic security of the state. Economic Security Bulletin, 3, 276-281.
14. Gamonenko, S.S. (2014) Financial monitoring in the system of ensuring economic security. Scientific Notes of the Russian Academy of Entrepreneurship, 40, 131-135.
15. Compliance with anti-money laundering legislation by Russian real estate organizations: theory and practice Electronic resource. Retrieved from https://transparency.org.ru/wp-content/themes/transparency-child/special/realestateaml/doc/aml_ru.pdf
16. Electronic resource. Retrieved from https://12.rosstat.gov.ru/
17. Mankhambo, A. M. Examining The Challenges Faced By Real Estate Agents In Implementing Anti-Corruption And Anti-Money Laundering Requirements. Electronic resource. Retrieved from https://www.iaca.int/media/attachments/2023/06/06/macs-master-thesis-iaca-anita-moses-mankhambo--proofread---clean-12.03.2023_covers.pdf
18. Teichmann, F. M. J. (2023). Financial crimes in the real estate sector in Austria, Germany, Liechtenstein and Switzerland. Journal of Money Laundering Control, 26(2), 418-432.
19. Zamudio, I. (2019). Purchasing Real Estate Property in Colombia as a Money-laundering Tactic: Challenges in Developing Effective Regulations and Detection by Anti-money Laundering Organizations (Doctoral dissertation, Utica College).
20. Kirechu, P. E. T. E. R., & Vittori, J. O. D. I. (2020). The illicit allure of Dubai’s luxury property market. Dubai’s Role in Facilitating Corruption and Global Illicit Financial Flows, Carnegie Endowment for International Peace, 59-66. Washington, DC.
21. Barone, R. (2023). Home sweet home, how money laundering pollutes the real estate market: an agent based model. Journal of Economic Interaction and Coordination, 1-28.
22. Yusoff, Y. H., Azhar, A. S. M., Rafidi, F. I., Yunus, N., Azlan, N. J., & Yusop, R. (2023). Money Laundering: Factors Leading to Money Laundering in Gold Investment Company in Malaysia. Journal of Academic Research in Business and Social Sciences, 13(5), 1011-1019.
23. Engel, A. (2023). This one's a fixer upper: Anti-money laundering policies for Ontario's real estate sector.
24. Sharman, J. C. & Chaikin, D., 2009. Corruption and anti-money laundering systems: putting a luxury good to work. An International Journal of Policy, Administration and Institutions, 22(1), 27-45.

First Peer Review

Peer reviewers' evaluations remain confidential and are not disclosed to the public. Only external reviews, authorized for publication by the article's author(s), are made public. Typically, these final reviews are conducted after the manuscript's revision. Adhering to our double-blind review policy, the reviewer's identity is kept confidential.
The list of publisher reviewers can be found here.

The subject of the study. Based on the title, the article should be devoted to the study of threats to the economic security of the Republic of Mari El in the field of countering the legalization (laundering) of proceeds from crime in the real estate purchase and sale market. The research methodology is based on the use of data analysis and synthesis methods of a number of electronic resources. The author has carried out in-depth work on the selection of a system of sources (moreover, it should be noted the consistency of the selected sources). It is valuable that the text contains tables that allow you to visually see the results obtained. The relevance of the study of issues related to countering the legalization (laundering) of proceeds from crime is beyond doubt, because this is one of the most significant problems not only in Russia, but also around the world. Its solution will help solve the problem of capital outflow from Russia, and ensure a reduction in crime, and increase investment attractiveness, thereby having a positive impact on stimulating economic growth. Scientific novelty is partially present in the material submitted for review. This is due to the identified problems of countering the legalization (laundering) of proceeds from crime in the real estate purchase and sale market and ways to solve them. However, it reduces the impression that the author's judgments are largely in the nature of "slogans" without justification and explanation. Style, structure, content. From the point of view of the absence of colloquial expressions and journalistic statements, the style of presentation is scientific. The structure of the article by the author consists of 3 titles: introduction, results, conclusions. It seems advisable to supplement it with the paragraphs "research methodology", "Problem statement", "Discussion of the results obtained", "Directions for further research". This will allow you to delve deeper into the issues under consideration. In the introduction, the author outlined 1 goal and 1 task. We consider this methodologically incorrect. To achieve the goal, several tasks must be formulated or the formulation of the task must be excluded from the text. Under all tables, it is necessary to indicate the sources on the basis of which they were formed. The author's judgments are practically not justified: "In view of the large number of transactions carried out over the past 12 months in the Republic of Mari El, when using the Domclick service, the author sees the following solution to this problem: the Domclick service, when adding realtors /real estate agencies to work with the system, checks each of these persons for accounting in Rosfinmonitoring." If the number of transactions is large, how much is it possible to verify each of the persons? What is embedded in this opposition? How exactly should this check be carried out? What should it be carried out for? The author should also carefully proofread the article for spelling and punctuation errors: for example, there is no dot in the title, and "despite" is always written together. Bibliography. The bibliographic list consists of 16 titles, most of which are electronic resources. It is recommended to specify the dates of access to electronic resources. From the point of view of assessing the sufficiency of studying scientific publications, it should be noted that there are no foreign sources, although foreign literature has accumulated quite a lot of experience in countering the legalization (laundering) of proceeds from crime. Also, the author has absolutely not studied the publications of 2022-2023 in the presence of 1 publication in 2020 and 1 publication in 2021. This suggests that current domestic sources have not been studied in practice. Appeal to opponents. The study of the literature on the research topic should be accompanied by a scientific discussion on each of the sources. This will allow us to delve into the content of the issues under consideration, as well as to show what the scientific and practical increase is in comparison with the basis already available in publications for countering the legalization (laundering) of proceeds from crime in the real estate purchase and sale market. Conclusions, the interest of the readership. Taking into account all the above, we conclude that the author has chosen an actual topic, the issues are mostly revealed superficially. It seems that after a qualitative revision, the article will be of interest to a wide range of people.

Second Peer Review

Peer reviewers' evaluations remain confidential and are not disclosed to the public. Only external reviews, authorized for publication by the article's author(s), are made public. Typically, these final reviews are conducted after the manuscript's revision. Adhering to our double-blind review policy, the reviewer's identity is kept confidential.
The list of publisher reviewers can be found here.

The subject of the research of the reviewed article is threats to the economic security of the subject of the Russian Federation in the field of countering the legalization (laundering) of proceeds from crime in the real estate purchase and sale market. The research methodology is based on such general methods of scientific knowledge as comparison, collection and processing of statistical data, synthesis of theoretical and practical material, in the course of the work, the authors rely on the developments of Russian and foreign scientists on the problems of economic security in the field of countering the legalization (laundering) of proceeds from crime. The information basis for the study was the open data of the Domclick service and the official website of Rosfinmonitoring. The authors attribute the relevance of the work to the increased level of criminalization of the real estate sector in the provision of intermediary services for real estate purchase and sale transactions. The scientific novelty of the reviewed research consists in generalizing the theoretical provisions on economic security in the field of countering the legalization (laundering) of proceeds from crime in the real estate purchase and sale market. Structurally, the following sections are highlighted in the article: Introduction, Literature review, Analysis of legislation on registration of organizations and individual entrepreneurs engaged in transactions with cash or other property, Research results, Conclusions and Bibliography. The author has reviewed studies that address the issues of income legalization in the Russian and foreign real estate purchase and sale markets, reviewed legislation on registration of organizations and individual entrepreneurs in the real estate industry. The publication contains identified real estate agencies that are not registered with Rosfinmonitoring and have not limited the viewing of information about their activities on the domclick website, the number of employees in each such company and the number of transactions on the portal over the past year are indicated. In addition, information is provided about real estate agencies operating in the Republic of Mari El and registered with Rosfinmonitoring. The article indicates the possibility of using a scheme bypassing the "anti-laundering legislation", when realtors do not participate in a real estate purchase and sale transaction, but settlements are made in cash and a change in legislation is proposed, in particular, it is proposed to assign responsibilities to developers who sell real estate independently, without involving agencies and realtors, to organize internal control in in accordance with federal legislation and their mandatory registration with Rosfinmonitoring. The bibliographic list includes 24 sources – electronic Internet resources, scientific publications on the topic in Russian and English. The text of the publication contains targeted references to the list of references confirming the existence of an appeal to opponents. From the reserves for improving the presented materials, it can be noted that Figure 1 is uninformative, does not reflect the results of the study and can be omitted without prejudice to the content of the article. The reviewed material corresponds to the direction of the journal "National Security / nota bene", may arouse interest among readers, and is recommended for publication.