The Compliance Agreement is an institute that perpetrators of tax crimes generally turn to to avoid a trial, first, and then a custodial sentence. It is the alleged criminal and not the prosecution who proposes it. And if he offers it, it is because his lawyer will have advised him because he understands that it is the best alternative for him.
The premise of the proposed compliance agreement is the acknowledgment by the alleged perpetrator of a tax offense that he or she has in fact committed the offense. The perpetrator of the crime continues to enjoy the presumption of innocence, but a presumption of innocence linked to the admission of the criminal act. The presumption of innocence is preserved until the compliance agreement is brought to the attention of the judge and he validates it.
