Criminal Tax, Money Laundering, and Bank Secrecy Act Litigation

Peter D. Hardy
Main and Supplemental Author
Carolyn H. Kendall
Supplemental Author


An expert analysis of the law and procedure relating to federal criminal cases handled by the IRS and DOJ, addressing the pragmatic and strategic challenges at every stage of litigation  

Main Volume Information

The increase in the scope and complexity of criminal cases handled by the Internal Revenue Service (IRS) and federal prosecutors of the Department of Justice (DOJ) has magnified the need for an examination of the current law, procedure, and practical considerations regarding such cases. Criminal Tax, Money Laundering, and Bank Secrecy Act Litigation provides the critical analysis practitioners need when defending against a federal criminal case pursued by the IRS and DOJ. Covering the entire length of a case from beginning to end, the treatise discusses in detail the entire panoply of complex legal, factual, logistical, and tactical issues raised by such litigation.

Written by a lawyer who has served as both a prosecutor and defense attorney, this treatise provides a comprehensive and current overview of the law and procedure for IRS criminal cases, including investigations, indictment, pretrial practice, plea agreements, trial, and sentencing. This treatise describes how a tax or currency matter that began as a civil issue can turn into a criminal case, as well as the elaborate process for approval or rejection of a proposed tax prosecution. The insights provided in Criminal Tax, Money Laundering, and Bank Secrecy Act Litigation are relevant not to only a wide variety of lawyers such as defense attorneys and corporate counsel, but also to financial institutions, business and tax professionals, and federal government agencies.

Supplement Information 

The 2014 Cumulative Supplement covers: 

  • The government’s high-profile enforcement campaign against undisclosed offshore financial accounts, including the implementation of FATCA, the increasing investigation and regulation of banks, and the evolving voluntary disclosure programs for offshore accounts
  • Willfulness in criminal cases, and in civil cases involving offshore account reporting
  • The emerging regulation of virtual currency under the Bank Secrecy Act
  • The new DOJ policy on criminal and civil forfeitures in tax-related cases
  • The new amendment to the Federal Sentencing Guidelines regarding the definition of “tax loss”



Bloomberg BNA authors and editors are practicing professionals with insider perspectives and real-life experience. Learn more about this book’s authors and editors.
Peter D. Hardy is principal in the Philadelphia office of the law firm of Post & Schell PC, where he is part of its national White Collar Defense, Compliance & Risk Management Practice Group. He is a former criminal prosecutor at the Criminal Enforcement Section of the Tax Division of the Department of Justice in Washington, DC, and at the U.S. Attorney’s Office in the Eastern District of Pennsylvania. He is also a member of the American College of Tax Counsel.

Carolyn H. Kendall is an associate in the Internal Investigations & White Collar Defense Group of the law firm of Post & Schell P.C., in Philadelphia, PA.  She is a graduate of the University of Virginia School of Law and has served as a clerk for a federal judge of the United States Court of Appeals for the Seventh Circuit.   Her work includes matters involving potential criminal tax and money laundering violations, as well as allegations involving securities violations and other fraud and regulatory statutes.


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