While a bit vague, the description in Attorney General Pam Bondi's press release suggests the complicity of the closing agent.
Would your staff have spotted this? Or helped facilitate it?
"This scheme operated with straw buyers who used their names and credit to purchase numerous properties. Once the loan had been secured and records reflected a price well over the actual price paid to the seller, a variety of financial exchanges would take place to make the purchase appear legitimate. The laundered money would then go back to the closing agent's escrow account and be characterized in the records as the cash brought to the closing by the straw buyer."