U.S. DOJ Program for Swiss Banks

The purpose of this page is to supply general links for the U.S. DOJ Program.  I willl further populated this page as I have time.

DOJ Program for Swiss Banks, here.

Links to the DOJ Announcements:
  • Press release (8/29/13), here.
  • Joint Statement between the U.S. Department of Justice and the Swiss Federal Department of Finance (8/29/13), here.
  • Signed Joint Statement and Program, 8/29/13 (8/29/13), here.
  • DOJ Tax comments about the Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks (11/5/13), here.
  • DOJ Tax Further Comments about the Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks (6/5/14), here.
  • DOJ Tax Press Release, "Justice Department Reaches Final Resolutions Under Swiss Bank Program" (12/29/16), here.
  • DOJ Tax Swiss Bank Program (with spreadsheet of banks reaching category 2 NPA and links for documents), here.
  • DOJ Tax, "Offshore Compliance Initiative" listing press releases in reverse chronological order, here.
IRS Web Pages:
  • IRS Foreign Financial Institutions or Facilitators, here.  This lists the foreign financial firms and other facilitators (I often call these enablers) of U.S. tax evasion that have been plublicly identified as having some U.S. Government initiative (e.g., indictment or subsequent action, deferred prosecution agreement, nonprosecution agreement, John Doe Summons, etc.).  The foreign financial firms and other facilitators will have consequences that result in the public disclosure.  U.S. taxpayers having accounts with the foreign financial firms on that list will be required to pay a 50% OVDP miscellaneous offshore penalty rather than the 27 1/2% penalty normally required.  The list is supplemented by the IRS as new public disclosures are made.  (Note that this bump to 50% applies only if the taxpayer in OVDP does not opt out; if the taxpayer opts out, the taxpayer is effectively in an audit regime where any and all tax and FBAR penalties may apply for open years, so that a taxpayer might get a better or worse result on opt out.)
Links for Swiss Banks joining program:
  • I keep a list of the Swiss Banks that I am aware of that join the program.  The list is part of the spreadsheet I keep on the page above titled "Offshore Charges / Convictions Spreadsheet."  Click here to go to that page.  The spreadsheet is large.  For bank data, I have two worksheets -- one with the bank data and the other with the bank data analysis.  [Note, I only publish this spreadsheet periodically; I do separately publish blog entries as DOJ Tax announces Swiss Banks in category 2 reaching NPAs and provide the cumulative statistics each time I publish the blog.]
  • US Tax Program (seems to be periodically updated and sortable), here.  (Also has other pages of interest.)
Federal Tax Crimes Blog Entries on the program:  here.  (This is all the blogs which has a keyword of U.S. Swiss Initiative 2013; caveat, however, that I may not have key coded all entries.)  These can be sorted by date.