Melissa Wiley Explores Sources of IRS Criminal Investigations at ABA Midyear Tax Meeting
Most tax and white collar defense lawyers know that the Bank Secrecy Act (BSA), Title 31, requires businesses to keep records and file reports with FinCEN that can have a high degree of usefulness for regulatory and law enforcement agencies. But what may not be as well-known is that the IRS Criminal Investigation (CI) is actually the largest user of such BSA data. With the passing of the Corporate Transparency Act (CTA) which requires even more FinCEN disclosures and reporting requirements, the IRS CI will now have another treasure trove to flex its data mining skills. This panel will cover how the How, Why and What’s Next of the IRS CI’s access, use, and sharing of information found under the BSA and the CTA reporting regimes.