The Department of Justice has announced a program encouraging Swiss banks to cooperate in ongoing U.S. investigations of the use of foreign bank accounts to commit tax evasion. The program is available only to banks not currently under criminal investigation by the Department of Justice for offshore activities. Participating Swiss banks will be required to do the following:
· Agree to pay substantial penalties
· Make a complete disclosure of their cross-border activities
· Provide detailed information on an account-by-account basis for accounts in which US taxpayers have a direct or indirect interest
· Cooperate in treaty requests for account information
· Provide detailed information as to other banks that transferred funds into secret accounts or that accepted funds when secret accounts were closed
· Agree to close accounts of account holders who fail to come into compliance with US reporting
Banks meeting all of the above requirements will be eligible for non-prosecution agreements. Banks currently under criminal investigation related to their Swiss banking activities, and all individuals, are expressly excluded from the program.
For the full Department of Justice announcement, click here.