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Criminal Charges Filed Against Bank Julius Baer of Switzerland with Deferred Prosecution Agreement Requiring Payment of $547 Million, as Well as Guilty Pleas of Two Julius Baer Bankers

On February 4, Zurich-based Bank Julius Baer & Company entered into a DPA, agreeing to pay $547 million and admitting that it knowingly assisted many of its U.S. taxpayer clients in evading their tax obligations under U.S. law. Two of the bank’s financial advisors, Daniela Casadei and Fabio Frazzetto, pleaded guilty to conspiring to help U.S. taxpayers hide their assets in offshore accounts.  Both individuals had been previously charged in 2011 but remained at large
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Justice Department Reaches its Final Three Resolutions under Category 2 of its Swiss Bank Program

The Justice Department ended this phase of its Swiss Bank Program, which, since March 30, 2015, has provided a path for 80 Swiss banks to resolve potential criminal liability in the United States. The Department has imposed a total of more than $1.36 billion in penalties under the Program.  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 non-prosecution
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28 Banks Reach Resolutions Under Justice Department’s Swiss Bank Program

In November and December, 28 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
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Seven Banks Reach Resolutions Under Justice Department’s Swiss Bank Program

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
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Seven Banks Reach Resolutions under Justice Department’s Swiss Bank Program

In August, a total of seven 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 non-prosecution agreements (“NPAs”) with DOJ.  Under the NPAs, each bank must cooperate in related
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Eleven Banks Reach Resolutions under DOJ’s Swiss Bank Program

In July, a total of eleven 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 liabilities 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 non-prosecution agreements (“NPAs”) with DOJ.  Under the NPAs, each bank must cooperate in related
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Seven Banks Reach Resolutions under DOJ’s Swiss Bank Program

In June, seven banks reached resolutions under DOJ’s Swiss Bank Program.  The Swiss Bank Program provides an opportunity for Swiss banks to resolve potential criminal liabilities in the United States by disclosing possible tax-related criminal offenses in connection with undeclared U.S.-related accounts.  If a bank makes a complete disclosure and complies with other requirements of the program, it may enter into an NPA with DOJ.  Under the NPAs, each bank must cooperate in related criminal
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Vadian Bank AG Reaches Resolution Under Department of Justice Swiss Bank Program

On May 8, Switzerland-based Vadian Bank AG (“Vadian”), reached a resolution with DOJ’s Swiss Bank Program.  Announced in 2013, the Swiss Bank Program allows eligible Swiss banks to resolve potential criminal liability in the United States regarding tax-related offenses for undeclared U.S. accounts.  In the resolution, Vadian agreed to cooperate in criminal or civil proceedings, demonstrate its implementation of controls to stop misconduct involving undeclared U.S. accounts, and pay a $4,253,000 penalty, in exchange for
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Swiss Asset Manager Pleads Guilty in Federal Court to Conspiring with U.S. Taxpayers to Evade Federal Income Taxes and File False Tax Returns

On March 31, Peter Amrein, a former asset manager at a Swiss firm, pled guilty to one count of conspiring to defraud the IRS, to evade federal income taxes, and to file false federal income tax returns.  According to the government, Amrein, a Swiss citizen, worked with a Swiss attorney to establish sham foundations that were used to maintain client assets.  Amrein also advised clients on ways to send funds back to the United States
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DOJ Announces First Bank to Reach Resolution Swiss Bank Program

On March 30, DOJ announced that BSI SA, one of the ten largest private banks in Switzerland, was the first bank to reach a resolution under DOJ’s Swiss Bank Program, agreeing to pay a $211 million penalty.  The program provides a path for Swiss banks that believe they may have committed tax-related criminal offenses in connection with undeclared U.S.-related accounts to resolve potential liability.  In exchange for making a complete disclosure, cooperating in treaty requests,
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Bank Leumi Enters into Deferred Prosecution Agreement for Assisting U.S. Taxpayers in Hiding Assets in Offshore Bank Accounts

On December 22, Bank Leumi le-Israel, B.M., an Israeli international bank, and its subsidiaries in the United States, Switzerland and Luxembourg as well as The Bank Leumi le-Israel Trust Company Ltd. (collectively, the “Bank Leumi Group”) entered into a deferred prosecution agreement with the Department of Justice that defers prosecution on a criminal information charging the bank with aiding and assisting in the preparation and presentation of false tax returns and other documents to the
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Court Authorizes IRS To Issue Summonses for Records Relating to U.S. Taxpayers Who Used Services of Sovereign Management & Legal, Ltd., to Conceal Offshore Accounts, Assets, Or Entities

On December 18, U.S. District Judge Vernon S. Broderick, of the Southern District of New York, signed an order authorizing the IRS to issue summonses requiring FedEx, DHL, UPS, Western Union, the Federal Reserve Bank of New York, Clearing House Payments Company, and HSBC Bank USA to produce information about U.S. taxpayers who may be evading or have evaded federal taxes by using the services of Sovereign Management & Legal, Ltd. (“Sovereign”), to establish, maintain,
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Former Director of Operations for Bernard L. Madoff Investment Securities and Four Employees Sentenced for Role in Madoff’s Massive Fraud

  • On December 8, following a six-month trial and conviction in the Southern District of New York, Daniel Bonventre, the former Director of Operations for Bernard L. Madoff Investment Securities LLC, was sentenced to 10 years in prison for his role in Madoff’s multibillion dollar Ponzi scheme and ordered to forfeit more than $155.5 billion.  According to the Government, Bonventre directed that false entries be made in the general ledger that concealed the scope of Madoff

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Former United Commercial Bank CFO Convicted to Conspiracy to Mislead Auditors

On December 9, Craig S. On pleaded guilty in the Northern District of California to one count of conspiracy to make a materially false and misleading statement to an accountant.  On is the former Chief Financial Officer of UCB, which was headquartered in San Francisco.  On November 6, 2009, UCB was taken over by the FDIC.  On admitted to engaging in a conspiracy with others to deceive UCB auditors by manipulating the bank’s books and
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United States Files Lawsuit Against Deutsche Bank for Engaging in Abusive Scheme to Avoid Federal Income Taxes

On December 8, Manhattan U.S. Attorney Preet Bharara announced that the United States has filed a lawsuit against Deutsche Bank and other entities alleging that they participated in a series of transactions that amounted to fraudulent conveyances for the purpose and effect of leaving the United States Treasury with a significant, uncollectable tax bill.  According to the complaint, in order to avoid paying more than $100 million in taxable gain as a result of appreciation
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Credit Suisse Sentenced for Conspiracy to Help U.S. Taxpayers Hide Offshore Accounts from Internal Revenue Service

On November 19, Credit Suisse AG was sentenced in the Eastern District of Virginia for conspiracy to aid and assist U.S. taxpayers in filing false income tax returns and other documents with the IRS.  Specifically, Credit Suisse was ordered to pay a fine of approximately $1.136 billion to the Department’s Crime Victims Fund and restitution of $666.5 million to the IRS.  Credit Suisse previously pleaded guilty to the conspiracy on May 19 pursuant to a
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Firm Owner Admits Paying $1 Million in Bribes to J.P. Morgan, GMAC

On September 26, Israel Hechter, the owner of San Diego investment firms Ocean 18 LLC and Note Tracker Corp., pled guilty to one count of conspiracy to commit bank bribery and tax evasion in connection with illicit payments he made to bank insiders at J.P. Morgan Chase Bank, GMAC Mortgage, LLC, and National City Bank.  According to his plea agreement, in exchange for the bribes, the bankers arranged for Hechter to win bids to purchase
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Former Credit Suisse VP Sentenced to Time Served, Ordered to Forfeit $150,000 for Concealing Mortgage-Backed Securities Losses

On July 31, former Credit Suisse Vice President Salmaan Siddiqui was sentenced in the Southern District of New York to time served and $150,000 in forfeiture in connection with a scheme to hide more than $100 million in losses in mortgage-backed securities.  Siddiqui pled guilty in February 2012 to falsifying books and records at the bank.  According to the government, in 2007 and 2008, Siddiqui and his co-conspirators fraudulently inflated the value of various mortgage-backed
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Attorney Sentenced to Six Months for Tax Fraud

On July 30, former Jenkens & Gilchrist P.C. attorney Erwin Mayer, who pled guilty in 2010 in the Southern District of New York to participating in a $7 billion tax shelter scheme, was sentenced to six months in prison and ordered (along with his co-defendants) to forfeit $220 million.  Jenkens & Gilchrist closed in 2007 after entering into a nonprosecution agreement with the Department.  According to the government, Mayer helped develop and market fraudulent tax
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Swiss Offshore Tax Evasion Enabler Pleads Guilty

On April 30, Swiss citizen Josef Dorig pled guilty in the Eastern District of Virginia to conspiring to defraud the Internal Revenue Service in connection with his work as the owner of a trust company in Switzerland.  According to the government, from 1996 to 2011, Dorig helped U.S. taxpayers evade taxes by concealing their assets and income in secret bank accounts held in the names of sham entities at a unidentified Swiss bank.  Dorig faces
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Congressman Michael Grimm Indicted

On April 28, Loretta Lynch, the U.S. Attorney for the Eastern District of New York, announced a 20-count indictment charging Congressman Michael Grimm with five counts of mail fraud, five counts of wire fraud, three counts of aiding and assisting in the preparation of false federal tax returns, one count of conspiring to defraud the United States, one count of impeding the Internal Revenue Service, one count of health care fraud, one count of engaging
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Former Banker Pleads Guilty in Tax Evasion Scheme

On March 12, Andreas M. Bachmann, a Swiss citizen and a former banking and investment advisor for U.S. customers at a global financial institution, pled guilty to conspiring to defraud the IRS.  According to court documents, between 1994 and 2006 Bachmann engaged in a wide-ranging conspiracy to assist U.S. customers in evading their income taxes by concealing assets and income in Swiss bank accounts.  Bachmann traveled to the U.S. twice each year to provide these
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