In September and October, a total of 15 banks reached resolutions under DOJ’s Swiss Bank Program.  Since 2013, the Swiss Bank Program has provided a path for Swiss banks to resolve potential criminal liability in the United States.  In exchange for complying with certain requirements, including complete disclosure of possible tax-related criminal offenses in connection with undeclared U.S.-related accounts, the banks entered into NPAs with DOJ.  Under the NPAs, each bank must cooperate in related criminal or civil proceedings, show implementation of controls to stop tax-related misconduct and pay penalties.  To mitigate its penalty, each bank will encourage its U.S. account holders to become compliant with their U.S. tax and disclosure obligations, including through participation in the IRS Offshore Voluntary Disclosure Program.

Related preceding post