IRS CI Highlights “Top 10 Cases” and “Banner Investigative Results” in 2025

The Internal Revenue Service (IRS) recently published two press releases touting the success of its enforcement efforts in 2025. While these press releases highlight the IRS’ enforcement initiatives over the past year, they also provide insight into the IRS’ ongoing enforcement priorities heading into 2026. Here are some key insights from Texas IRS dispute lawyer Lawrence Brown:

Cryptocurrency, Gaming and Gambling, and Pandemic-Era Fraud Remain Among the IRS’ Top Enforcement Priorities

Combating cryptocurrency-related tax fraud has been among the IRS’ top enforcement priorities for several years now. Ever since the explosion in popularity of Bitcoin and other cryptocurrencies, the IRS has struggled to enforce compliance with U.S. taxpayers’ crypto-related tax obligations.

Gaming and gambling-related tax fraud are growing concerns for the IRS as well. With more states relaxing their gaming and gambling laws, and with sports betting and prediction market apps thriving, the IRS is struggling to stay on top of widespread underreporting and underpayment in these areas. As a result, it is using high-profile enforcement cases to attempt to warn taxpayers of the risks of noncompliance. Targeting tax fraud related to more-traditional gaming and gambling operations remains a top IRS enforcement priority as well.

Pandemic-era fraud also remains a top enforcement priority for the IRS heading into 2026. This includes fraud under the Paycheck Protection Program (PPP), Economic Injury Disaster Loan (EIDL) program and Employee Retention Credit (ERC) program, as well as other programs intended to help low-income businesses and families that were struggling during the COVID-19 pandemic.

For example, the IRS’ “Top 10 Cases of 2025” include cases targeting:

• The “Feed Our Future” scheme that involved the theft of more than $250 million in federal funds intended to feed children from low-income families during the COVID-19 pandemic.
• A bribery scheme involving more than $10 million in pandemic-era relief funds.
• An embezzlement and tax fraud scheme involving more than $24 million in gambling and gaming revenue.
• A cryptocurrency “mixing” scheme that involved more than $327 million in laundered proceeds from criminal activity.

The IRS’ 2025 Annual Report also emphasizes the agency’s ongoing enforcement efforts in these areas. The IRS highlights the “Feed Our Future” case in a press release announcing the release of the 2025 Annual Report and the IRS’ “banner investigative results” from last year, and the report itself discusses the IRS’ past and ongoing efforts to target both cryptocurrency-related fraud and pandemic-era fraud. While the report does not mention gaming and gambling fraud specifically, it highlights the IRS’ enforcement efforts in related areas, including general tax evasion and money laundering.

The IRS is Targeting Both Banks and Bank Clients for Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) Violations

Along with the areas discussed above, the IRS is also continuing to prioritize enforcement in the area of anti-money laundering/Bank Secrecy Act (AML/BSA) compliance. This includes prioritizing enforcement of banks’ AML/BSA compliance obligations as well as individual taxpayers’ compliance obligations with respect to cross-border transactions and offshore accounts.

Under the BSA and other applicable federal laws, banks in the U.S. and abroad have obligations to detect, monitor, and report suspicious transactions and the parties involved. The IRS can—and does—act on information provided by banks under the BSA, and in 2025 the IRS’ Criminal Investigation division launched CI-FIRST (Feedback in Response to Strategic Threats)—which the IRS describes as, “flagship public-private partnership to modernize how IRS-CI works with financial institutions.” In AML/BSA enforcement cases, individual taxpayers can face civil or criminal penalties related to violations including (but not limited to):

• Money laundering transactions used to obscure the source of income from illicit activities;
• Transactions with sanctioned individuals and organizations;
• Failure to disclose offshore accounts and other foreign financial assets; and,
• Use of sophisticated offshore tax schemes to evade federal tax liability.

In its 2025 Annual Report, the IRS highlights enforcement cases involving TD Bank and Credit Suisse. In the TD Bank case, the IRS found that the bank, “intentionally did not automatically monitor all domestic automated clearing house (ACH) transactions . . . [which] amounted to approximately $18.3 trillion of unmonitored transaction activity.” In the Credit Suisse case, the bank, “pleaded guilty [to] conspiring to help U.S. taxpayers hide more than $4 billion in at least 475 offshore accounts from the IRS.”

If a bank fails to prevent a customer from inadvertently engaging in federal tax evasion, this does not insulate the taxpayer from liability. If a bank works with a taxpayer to help the taxpayer intentionally evade federal tax liability, both parties can face serious criminal charges under the BSA and other pertinent federal statutes.

The IRS is “Prioritizing Time and Resources for Maximum Impact”

In its press release announcing the publication of its 2025 Annual Report, the IRS also states that it is, “prioritizing time and resources for maximum impact.” While the IRS makes this statement in reference to its efforts to primarily target tax crimes while letting the U.S. Department of Justice (DOJ) and other law enforcement authorities pursue investigations in other areas, this also speaks to the IRS’ prioritization of cases involving high-income and high-net-worth taxpayers—including both individuals and businesses.

By stating its intent to focus on cases with “maximum impact,” the IRS is sending a clear message that high-income and high-net-worth taxpayers are among those at greatest risk of facing scrutiny. To avoid scrutiny, these taxpayers must not only prioritize compliance going forward, but they must also proactively address any outstanding enforcement risks, whether through amended filings, streamlined filings, voluntary disclosures or other means.

Request a Call with Texas IRS Dispute Lawyer Lawrence Brown

Lawrence Brown is a highly experienced Texas IRS dispute lawyer who represents high-income and high-net-worth clients in significant federal tax controversies. This includes both IRS enforcement actions and proactive efforts to mitigate taxpayers’ liability exposure. If you have concerns about facing IRS scrutiny in 2026, we invite you to contact us for more information. To request a call with Mr. Brown, please call 888-870-0025 or contact us confidentially online today.