FINES

Under a non-prosecution agreement, Vadian will pay a $4.253 million penalty, demonstrate that it put in controls to stop misconduct in undeclared U.S. accounts and cooperate in related legal proceedings.[51]

BSI[52], S.A. (BSI) $211m (the first non-prosecution agreement under the Swiss bank program).

2014

Bank Leumi[53] $270m.

Credit Suisse[54] $2.6BN (Credit Suisse Group AG, Switzerland’s second largest bank, pleaded guilty to aiding U.S. taxpayers in evading tax and agreed to pay a penalty of $2.6 billion).

$1.8B to the DoJ for the US Treasury
$100M to the Federal Reserve
$715M to the New York State Department of Financial Services

Swiss Partners. $4.4M. [55]

2013

Liechtensteinische Landesbank AG. $23.8M.[56]

Wegelin & Co. $57.8M.[57]

2009

UBS[58] $780M (in a deferred-prosecution agreement and provide financial information for almost 4,500 U.S. clients).[59]
- $380 million in profits from maintaining the US cross-border business and
- $400 million for US federal backup withholding tax required to be withheld by UBS, together with interest and penalties, and restitution for unpaid taxes.[60]

Pending:

On December 8, 2014, the DOJ filed a lawsuit against Deutsche Bank AG in federal court in New York for tax fraud alleging the bank engaged in a series of transactions designed to fraudulently shift tax liability to an underfunded special purpose vehicle. The government is seeking $190 million in unpaid taxes, penalties and interest. On December 19, 2014, a federal judge in Manhattan approved a special summons directed at Sovereign Management & Legal, a Panamanian legal services firm alleged to have helped U.S. clients evade taxes through anonymous banking services.

Julius Baer Seeking Non Prosecution Agreement Over Tax Crimes.[61]

CIBC FirstCaribbean International Bank Limited, its predecessors, subsidiaries, and affiliates.

The IRS also recovers money via is Offshore Voluntary Disclosure Program:

“The passage of FATCA coincided with the inception of the IRS’s Offshore Voluntary Disclosure Program (OVDP), which since 2009 has afforded U.S. taxpayers with previously undisclosed overseas assets the opportunity to disclose them and pay reduced penalties. The IRS reported that by 2014, the OVDP had collected $6.5 billion through voluntary disclosures from 45,000 participants. “IRS Offshore Voluntary Disclosure Efforts Produce $6.5 Billion; 45,000 Taxpayers Participate,” available at

http://www.irs.gov/uac/Newsroom/IRS-Offshore-Voluntary-Disclosure-Efforts-Produce-$6.5-Billion;-45,000-Taxpayers-Participate

(last visited July 31, 2015).”

DoJ Response, “Case: 3:15-cv-00250-TMR Doc #: 16”. August 12, 2015, page 5.

“John Doe” Summonses Issued to Discover U.S. Taxpayers with Offshore Bank Accounts:

Belize Bank International Limited and Belize Bank Limited for records of correspondent accounts at Bank of America, N.A. and Citibank, N.A.[62]
UBS AG for records of Swiss bank Wegelin & Co.’s correspondent account at UBS

Wells Fargo, N.A., for records of the Barbados-based Canadian Imperial Bank of Commerce FirstCaribbean International Bank (FCIB)

[1] http://www.justice.gov/opa/file/796881/download

[2] http://www.justice.gov/opa/file/795876/download

[3] http://www.justice.gov/opa/file/795676/download

[4] http://www.justice.gov/opa/file/794551/download

[5] http://www.justice.gov/opa/file/794556/download

[6] http://www.justice.gov/opa/file/794546/download

[7] http://www.justice.gov/opa/file/793611/download

[8] http://www.justice.gov/opa/file/793151/download

[9] http://www.justice.gov/opa/file/792896/download

[10] http://www.justice.gov/opa/file/792901/download

[11] http://www.justice.gov/opa/file/790411/download