On April 18, the Internal Revenue Service (“IRS”) issued a draft version of Form 1099-DA, a proposed information reporting form regarding certain digital asset sales and exchanges that “digital asset brokers” will need to...more
4/24/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Digital Assets ,
Digital Wallets ,
Internal Revenue Code (IRC) ,
IRS ,
Know Your Customers ,
Reporting Requirements
In this episode, we are joined by Special Agent Jonathan Schnatz, Senior Analyst with IRS Criminal Investigation. Special Agent Schnatz will discuss his work with an international law enforcement and tax compliance group, and...more
3/5/2024
/ Criminal Investigations ,
Criminal Liability ,
Criminal Prosecution ,
Income Taxes ,
IRS ,
Tax Evasion ,
Tax Fraud ,
Tax Liability ,
Tax Planning ,
Tax Returns ,
White Collar Crimes
Treasury Offers Something for Everyone to Comply With: Trades and Businesses, Banks, Crypto Exchangers and Individuals -
On May 21, 2021, the U.S. Department of Treasury (“Treasury”) released its American Families Plan Tax...more
ABA Tax Fraud Panel to Discuss IRS CI and Crypto Criminals -
The Internal Revenue Service – Criminal Investigation (IRS CI) has made it clear that it is focusing on the abuse of digital currencies to further tax evasion,...more
12/10/2019
/ Bitcoin ,
Capital Gains ,
Child Pornography ,
Corruption ,
Criminal Investigations ,
Cryptocurrency ,
Cyber Crimes ,
Dark Web ,
Data-Sharing ,
Digital Currency ,
Digital Wallets ,
Enforcement Actions ,
Exploitation ,
Extradition ,
Financial Crimes ,
Income Taxes ,
Indictments ,
IRS ,
Money Laundering ,
OECD ,
Popular ,
Reporting Requirements ,
Tax Evasion ,
Virtual Currency
The Treasury Inspector General for Tax Administration, or TIGTA, issued last month a Report, entitled The Internal Revenue Service’s Bank Secrecy Act Program Has Minimal Impact on Compliance...more
11/1/2018
/ Bank Secrecy Act ,
BSA/AML ,
Failure to Comply ,
Financial Crimes ,
FinCEN ,
IRS ,
Recordkeeping Requirements ,
Regulatory Violations ,
Reporting Requirements ,
Strict Compliance ,
U.S. Treasury
Last week, a federal magistrate judge in the Northern District of California granted in part and denied in part a motion by the IRS to enforce a “John Doe” summons served on Coinbase, Inc., which operates a virtual currency...more
12/7/2017
/ Bitcoin ,
Coinbase ,
Currency Exchange ,
Customer Information ,
Digital Currency ,
Financial Services Industry ,
Financial Transactions ,
IRS ,
John Doe Investigation ,
Know Your Customers ,
Money Laundering ,
Popular ,
Summons ,
Tax Avoidance ,
Virtual Currency
As the world now knows, an indictment against Paul Manafort, Jr., a former campaign chairperson for now-President Donald Trump, and Manafort’s associate, Richard Gates III, was unsealed yesterday. ...more
10/31/2017
/ Bank Secrecy Act ,
Criminal Conspiracy ,
Criminal Investigations ,
FBAR ,
FBI ,
FinCEN ,
Foreign Agents ,
Geographic Targeting Order ,
Indictments ,
IRS ,
Money Laundering ,
Offshore Banks ,
Offshore Funds ,
Political Campaigns ,
Political Corruption ,
Popular ,
Real Estate Investments ,
Regulatory Violations ,
Reporting Requirements ,
Russia ,
Tax Evasion ,
Trump Administration ,
White-Collar Exemptions
In this post, we consider the Department of Justice’s (DOJ) Office of the Inspector General report (OIG Report), released on March 29, 2017, evaluating the DOJ’s oversight of its cash seizure and forfeiture operations. This...more
4/12/2017
/ Asset Seizure ,
Civil Forfeiture ,
Criminal Investigations ,
Data Collection ,
DEA ,
Department of Justice (DOJ) ,
Forfeiture ,
IRS ,
Money Laundering ,
OIG ,
Tax Structuring
Forfeiture actions by Internal Revenue Service Criminal Investigation (IRS CI) based on alleged structuring activity have come under fire, yet again. Specifically, the Treasury Inspector General for Tax Administration (TIGTA)...more
Under Internal Revenue Code section 7609(f), the IRS may issue a “John Doe” administrative summons to discover the identities of unknown taxpayers. A “John Doe” summons can be a powerful enforcement tool because it allows the...more
2/7/2017
/ Bitcoin ,
Department of Justice (DOJ) ,
Digital Currency ,
Enforcement Actions ,
Financial Institutions ,
Financial Services Industry ,
Internal Revenue Code (IRC) ,
IRS ,
John Doe Investigation ,
Money Laundering ,
Summons ,
Swiss Banks ,
Tax Evasion ,
Technology ,
Virtual Currency
The field of forfeiture saw significant action in 2016. The IRS offered to return forfeited funds used in structuring, but Congress still may clip its ability to forfeit such funds. Meanwhile, DOJ renewed a controversial...more
2/7/2017
/ Asset Seizure ,
Bank Secrecy Act ,
BSA/AML ,
Criminal Investigations ,
Currency Transaction Reports (CTR) ,
Department of Justice (DOJ) ,
Financial Institutions ,
Forfeiture ,
IRS ,
Luis v United States ,
Money Laundering ,
SCOTUS ,
Sixth Amendment
As part of the U.S. Treasury Department's ongoing efforts to prevent bad actors from using U.S. companies to conceal money laundering, tax evasion, and other illicit financial activities, the Financial Crimes Enforcement...more
5/11/2016
/ Bad Actors ,
Bank Holding Company Act ,
Beneficial Owner ,
Covered Financial Institutions ,
Due Diligence ,
Financial Institutions ,
FinCEN ,
IRS ,
Limited Liability Company (LLC) ,
Panama Papers ,
Reporting Requirements ,
Tax Evasion
Maintaining a foreign bank or other financial account is not illegal. Such accounts are increasingly common, as the globe shrinks. However, in the case of U.S. citizens or residents (and certain non-residents), failing to...more