In this article, Timothy O'Toole discusses litigation challenges stemming from the International Consortium of Investigative Journalists' (ICIJ's) recent publishing of reports describing the alleged involvement of a number of individuals in offshore bank accounts, reportedly based on documents obtained from the Panama-based Mossack Fonseca law firm. "Such reports indicate that the Panama Papers may not simply generate news stories; they will ultimately likely wind up generating regulatory and criminal enforcement actions in the U.S. and around the world," O'Toole said. "As a result, it is worth thinking about what those actions might look like."