Criminal Investigation Enforced Structuring Laws Primarily Against Legal Source Funds and Compromised the Rights of Some Individuals and Businesses

The Chief, CI, should establish proper oversight and controls to prevent Consents to Forfeiture from being used by field offices as a general practice.

The Chief, Criminal Investigation (CI), should ensure that referrals of potential civil tax matters derived from Title 31 structuring leads are referred to the appropriate IRS business unit.

The Chief, CI, should (1) establish procedures that strive to assure consistent and fair outcomes in resolutions for similarly situated property owners and (2) monitor settlements to ensure that the procedures are working to assure consistency and fairness.

The Chief, CI, should use a checklist and coordinate with the respective USAO to determine on each case which information requested is restricted under the grand jury secrecy rules and, if restricted, whether an alternative document is available.