Friday, March 12, 2021

Rahn+Bodmer, Swiss Bank Category 1, Enters Deferred Prosecution Agreement (3/12/21)

UAO SDNY issued this press release titled:  Zurich’s Oldest Private Bank Admits To Helping U.S. Taxpayers Hide Offshore Accounts From IRS: Rahn+Bodmer Enters into Deferred Prosecution Agreement for Criminal Misconduct; Agrees to Pay $22 Million (3/12/21).  The deferred prosecution agreement (“DPA”) is here.  The DPA waives indictment and consents to the filing of a criminal information charging a single conspiracy count encompassing both a defraud conspiracy and offense conspiracies (evasion, § 7201 and tax perjury, § 7206(1)).

The announcement and underlying documents assert a standard litany of misconduct that was typical of Swiss banks' actions to help U.S. taxpayers cheat on their taxes.  R+B is just the latest of the small group of Category 1 Swiss Banks that were under investigation when DOJ Tax offered its Swiss Bank Program.  According to my spreadsheet, 19 Banks are listed as Category 1 but I think there is some duplication in that number.  At any rate, it is a small number relative to all of the Swiss banks engaging in this type of misconduct.

My spreadsheet indicates the following for Category 1 Swiss Banks (with duplication in the number of banks (but not in total costs)

US DOJ Swiss Bank Program



Total Costs

   U.S. / Swiss Bank Initiative Category 1




These Category 1 DPAs should be distinguished from the nonprosecution agreements reached with Swiss Banks in other categories under the DOJ Swiss Bank Program where the Swiss banks resolving their U.S. tax criminal issues are listed here.

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