For example, if you are a produce importer or vehicle exporter, you routinely file paperwork with Customs and daily speak with them directly or through your broker. It’s part of the business. But those officials, who you’ve probably known for years, may start asking you or your broker, innocently enough it seems, about some questioned transactions. You feel obligated to answer, to maintain the status quo, to keep business flowing smoothly.
By way of another example, if you are a licensed real estate agent or licensed loan officer, a state or federal licensing agency may simultaneously investigate you while the IRS is investigating you. They will ask you questions and ask you to submit paperwork, sometimes signed, sometimes under oath.
These are known as parallel proceedings and they pose special problems for ongoing businesses. Michael has particular experience navigating the treacherous waters of parallel proceedings, keeping businesses and careers afloat, and even on course, during multiple and parallel government investigations.