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Tax Audits, Investigations and Global Enforcement: A Podcast

By Peter D. Hardy, Christopher A. Jones & Siana Danch on March 6, 2024
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Link to With Guest Speaker IRS Criminal Investigation Special Agent Jonathan Schnatz With Guest Speaker IRS Criminal Investigation Special Agent Jonathan Schnatz

We are very fortunate to have Special Agent Jonathan Schnatz as our guest speaker in this podcast on international efforts to investigate tax evasion and money laundering, and how they relate to criminal investigations and civil audits of U.S. businesses and individuals.

Special Agent Schnatz is a Senior Analyst with IRS Criminal Investigation (“IRS CI”) where he chairs the Professional Enabler Group as part of the Joint Chiefs of Global Tax Enforcement (J5), an international law enforcement and financial investigation collaborative dedicated to combatting transnational tax crime. Prior to this position, Jonathan was a Senior Analyst within International Operations, served as the Deputy Attaché at the US Embassy in London, UK, and a Supervisory Special Agent and Special Agent in the Philadelphia Field Office. Prior to his government service, he worked in public accounting and has a dual degree in Accounting and Finance from DeSales University.

In this podcast, we delve into Special Agent Schnatz’s work with the J5, what it does and how it operates, and why it focuses on professional enablers of tax and money laundering violations, such as lawyers. We then discuss how IRS CI works with its civil counterparts in the IRS in regards to enhancing the examinations of U.S. businesses and individuals for tax compliance. The podcast further examines why a civil audit of a business or individual might turn into a criminal investigation, and what factors IRS CI special agents look for.

Finally, we briefly discuss the Corporate Transparency Act (“CTA”), and how law enforcement agents may approach the CTA and the beneficial ownership information which will be collected under the CTA as an investigative resource.  The podcast was recorded before a March 1 district court ruling that the CTA is unconstitutional as written; FinCEN has indicated that it will comply with this ruling as to the particular plaintiffs “for as long as [the ruling] remains in effect.”

We previously have blogged on enforcement efforts by the J5, and efforts in general to combat cross-border tax evasion.  And we repeatedly have blogged on the growing focus on professional enablers of tax evasion and money laundering (here and here, just as examples).

We hope you enjoy the podcast.

If you would like to remain updated on these issues, please click here to subscribe to Money Laundering Watch. To learn more about Ballard Spahr’s Anti-Money Laundering Team, please click here.  To learn more about Ballard Spahr’s Tax Controversy Team, please click here.  Please click here to read our article on potential money laundering and client due diligence issues facing attorneys.

Peter D. Hardy

hardyp@ballardspahr.com | 215.864.8838 | view full bio

Peter is a national thought leader on money laundering, tax fraud, and other financial crime. He is the author of Criminal Tax, Money Laundering, and Bank Secrecy Act Litigation, a comprehensive legal treatise published by Bloomberg…

hardyp@ballardspahr.com | 215.864.8838 | view full bio

Peter is a national thought leader on money laundering, tax fraud, and other financial crime. He is the author of Criminal Tax, Money Laundering, and Bank Secrecy Act Litigation, a comprehensive legal treatise published by Bloomberg BNA.  Peter co-chairs the Practising Law Institute’s Anti-Money Laundering program, and serves on the Steering Committee for the Cambridge Forum on Sanctions & AML Compliance

He advises corporations and individuals from many industries against allegations of misconduct ranging from money laundering, tax fraud, mortgage fraud and lending law violations, securities fraud, and public corruption.  He also advises on compliance with the Bank Secrecy Act and Anti-Money Laundering requirements.  Peter handles complex litigation involving allegations of fraud or other misconduct.

Peter spent more than a decade as a federal prosecutor before entering private practice, serving as an Assistant U.S. Attorney in Philadelphia working on financial crime cases. He was a trial attorney for the Criminal Section of the Department of Justice’s Tax Division in Washington, D.C.

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Siana Danch

Siana Danch | danchs@ballardspahr.com | 215.864.8348 | view full bio

Siana focuses on regulatory compliance and enforcement, white collar defense, internal investigations, tax controversy and complex civil litigation. She advises financial institutions and other businesses on BSA/AML compliance, including issues relating to KYC…

Siana Danch | danchs@ballardspahr.com | 215.864.8348 | view full bio

Siana focuses on regulatory compliance and enforcement, white collar defense, internal investigations, tax controversy and complex civil litigation. She advises financial institutions and other businesses on BSA/AML compliance, including issues relating to KYC, beneficial ownership reporting, Suspicious Activity Report filings, Travel Rule compliance, Form 8300 filings, and other BSA/AML reporting and record keeping requirements.  Her work in the AML space includes the digital asset industry and related licensing requirements involving federal and state money-transmitter laws. Similarly, Siana represents financial institutions, other businesses and individuals in regards to conducting internal corporate investigations and defending against government criminal and civil investigations and proceedings, including as to allegations of fraud, money laundering, tax violations, and BSA/AML violations.  She also represents clients in tax controversy cases, from audit to IRS appeals to litigation.

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  • Posted in:
    Tax
  • Blog:
    Money Laundering Watch
  • Organization:
    Ballard Spahr LLP
  • Article: View Original Source

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