Swiss banks hoping to escape prosecution in the US will have to pay between 20 and 50 per cent of the untaxed American assets they held between 2008 and the end of this year, under an agreement published at the end of last week.
The agreement allows most banks to negotiate their own non-prosecution deals with the US Department of Justice (USDoJ), which has set out a programme specifying the scale of penalties and disclosure requirements to be imposed on each bank. The highest penalties will be imposed for accounts opened after February 2009.
The fourteen banks that are already under criminal investigation by the USDoJ cannot participate in the non-prosecution programme.
Banks that do wish to participate ? thought to number about 100 ? will have to make a complete disclosure of their cross-border activities to the USDoJ. Although the Swiss authorities say banks will not be allowed to disclose client data except in response to a treaty request for administrative assistance, the USDoJ statement says it will insist on ‘detailed information on an account-by-account basis for accounts in which US taxpayers have a direct or indirect interest.’
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It appears that this will be done through group treaty requests for bank account information, which the banks will have to agree to fulfil.
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