Dorig was indicted by superseding indictment in July 2011. See Criminal Charges for More Swiss Bank Enablers (Federal Tax Crimes Blog 7/21/11), here. One of his co-conspirators, Andreas Bachmann, pled guilty in March 2014. See Credit Suisse Banker Pleads Guilty to Tax Conspiracy (Federal Tax Crimes Blog 3/12/14; 3/13/14), here. (The latter blog names others indicted at the same time in addition to Dorig and Bachmann: Markus Walder, Marco Parenti Adami, Susanne D. Ruegg Meier, Roger Schaerer, Emanuel Agustoni, and Michele Bergantino; Schaerer is the Credit Suisse officer mentioned prominently in the NY probe of tax shelters, see NY State Agency Makes New Moves in Investigation of Credit Suisse (Federal Tax Crimes Blog 4/17/14), here.
Here are the key excerpts (emphasis supplied by JAT):
In a statement of facts filed with the plea agreement, Dörig admitted that between 1997 and 2011, while owning and operating a trust company, he engaged in a wide-ranging conspiracy to aid and assist U.S. customers in evading their income taxes by concealing assets and income in secret bank accounts held in the names of sham entities at a financial institution referred to in the superseding indictment as International Bank (IB), one of the biggest banks in Switzerland and one of the largest wealth managers in the world.
According to the statement of facts, from 1972 to 1996, Dörig worked for a subsidiary of IB. The subsidiary formed, managed and maintained nominee tax haven entities. Individuals concealed their assets by holding their accounts at IB in the names of these tax haven entities. During this time, the subsidiary managed and maintained over 100 sham entities for U.S. taxpayers committing tax evasion.
Also included in the statement of facts, in 1997, executives at the subsidiary devised a plan to spin off all of these sham entities into a new trust company, Dörig Partner AG, to be owned and operated by Dörig, who was then an employee of the subsidiary. Dörig was required to make his best efforts to keep the existing accounts at IB open and to ensure that any clients referred to him by IB would open new accounts at that institution.
According to the statement of facts, IB promoted Dörig Partner as a provider of various entity structures. The phone list used in IB’s New York representative office identified Dörig Partner as an external trust expert. Dörig Partner also sublet space from IB in an office tower where a private bank owned by IB was the major tenant.
As part of the conspiracy, Dörig traveled to the United States to introduce himself to new clients he had obtained as part of the spin-off. In the following years, he traveled to the United States with bankers from IB, including his co-defendants Markus Walder, Marco Parenti-Adami and Michele Bergantino, to meet with existing and prospective clients who already had undeclared accounts at IB but had been identified by the IB’s bankers as potential candidates for the use of a structure.
According to the statement of facts, although Dörig ostensibly controlled both the structure and the account at IB, in practice, many of the U.S. taxpayers with undeclared accounts controlled the assets in those accounts by dealing directly with IB bankers, often without either the knowledge or consent of Dörig.
According to the statement of facts, in 2008, IB ordered Dörig Partner to close accounts for the structures they managed. Dörig turned to an asset manager at a financial services firm in Zurich for assistance. The financial services firm maintained a master account in its own name at a private bank in Gibraltar, and then opened sub-accounts for Dörig’s clients at that bank to which Dörig transferred the funds from the clients’ undeclared accounts at IB. The financial services firm provided the Gibraltar bank only with the number associated with each sub-account and did not inform the bank of any information regarding the owners of the assets in the sub-accounts.I assume that IB is Credit Suisse.