Caroline D. Ciraolo participated in the panel titled "Collection Of Title 31 International Penalties" at the ABA Section of Taxation 2018 May Meeting

With the increase in international enforcement efforts and heightened focus on anti-money laundering and anti-tax evasion, individuals and entities are finding themselves subject to substantial civil penalties for failing to report foreign financial accounts and other violations of the Bank Secrecy Act. This panel reviewed the Title 31 civil penalties, the methods by which the United States can collect such penalties, available defenses, and best practices for pursuing collection alternatives.

Moderator: Caroline D. Ciraolo, Kostelanetz & Fink LLP, Washington, DC

Panelists: Sandra R. Brown, Hochman Salkin Rettig Toscher & Perez PC, Beverly Hills, CA; Jeremy N. Hendon, Department of Justice, Tax Division, Washington, DC; Niles Elber, Caplin & Drysdale Chartered, New York, NY