Two Ex-Julius Baer Bankers Return to U.S. to Face Charges (2/2/16)

There are several articles reporting that Daniela Casadei and Fabio Frazzetto, two former Julius Baier bankers, have voluntarily come to the U.S., have entered not guilty pleas, but, reportedly will enter guilty pleas when Julius Baer resolves its case with a $547 million payment.  E.g., Nate Raymond, Two ex-Julius Baer bankers plead not guilty in U.S. tax case (Reuters 2/2/16), here.  David Voreacos, Patricia Hurtado and Giles Broom, Julius Baer Bankers Said Ready to Plead Guilty in Tax Case (BloombergBusiness 2/2/16), here.

Prior reporting involving their initial indictment is Swiss Bankers / Enablers Indictment; Reputedly Julius Baer Related (Federal Tax Crimes Blog 10/11/11), here.

I recently reported that Julius Baer appeared to be on the verge of settling its criminal tax investigation.  Julius Baer Group Ltd. Expects to Pay $547 Million to US to Conclude Criminal Investigation (Federal Tax Crimes Blog 12/31/15), here.  In that blog I said:

3.  Two Julius Baer employees, Daniela Casadei and Fabio Frazzetto, were indicted in 2011, but have not yet come to the U.S., so the case has not proceeded beyond the indictment stage.  See BloombergBusiness article.  And, they are reported to still be with Julius Baer.  I would not expect that their criminal indictments will be resolved by the resolution with Julius Baer and would expect that their relationship with Julius Baer will be terminated.  (I am surprised that Julius Baer had not already terminate them in an attempt to curry favor with DOJ.)

I surmise that the report identifying them as "Ex-Julius Baer bankers" suggests that they are no longer with Julius Baer.  Perhaps more importantly, It is not clear whether, since they are not extraditable, Julius Baer induced them to come to the U.S. as a component of its appeasement with the U.S.   As to the reputed guilty plea, I can't imagine that they came back without first achieving a plea deal they deemed beneficial.