On August 17, Principal Deputy Assistant Attorney General Caroline D. Ciraolo delivered remarks at the Panama Bankers Association Anti-Money Laundering Conference on the Tax Division’s offshore tax enforcement efforts.  Ciraolo stated that offshore tax enforcement is one of the Tax Division’s highest priorities.  She explained that the one role of the Tax Division is to petition the federal courts to enforce IRS requests for records related to taxpayers’ offshore assets and activities, sometimes through “John Doe summonses,” in which the government seeks information on a class of individuals whose identities are unknown.  Ciraolo added that the Tax Division also investigates and prosecutes U.S. taxpayers who evade taxes and the facilitators who help them.  She noted that since 2008, DOJ has criminally charged over 160 accountholders and over 50 facilitators.  Lastly, Ciraolo spoke about DOJ’s Swiss Bank Program, which allowed Swiss banks to enter into a non-prosecution agreement with DOJ in exchange for complete disclosure of their cross-border activities, detailed account information, and a penalty.  Through the program, DOJ executed 78 agreements and imposed more than $1.3 billion in penalties.  DOJ Press Release