Table 1 Activities of banks as described by the DoJ
From: The U.S. Tax Program for Swiss banks: what determined the penalties?
ACTIVITIES | |||
|---|---|---|---|
A1 [75] | Post withholding service | A16 [19] | Assisting the bank’s clients in concealing assets and income from IRS |
A2 [61] | Numbered accounts/pseudonyms/code name | A17 [20] | maintaining insurance wrappers |
A3 [3] | Assisted in the falsification of documents | A18 [39] | (Account closure via) excessive cash, precious metal withdrawal, cashing checks, bearer shares, or fictitious donations |
A4 [37] | Cash cards or credit cards (Anonymous cash withdrawal) | A19 [29] | Transfer of assets from closed accounts to non-US-related accounts or accounts at other banks held by non-US relatives/friends or removing name of US taxpayer clients from joint accounts |
A5 [2] | Lombard loans secure by (uncleared) assets | A20 [18] | Permitted relationship managers to meet or have direct contact with US beneficial owner, even such who did not have powers of attorney over the entity accounts |
A6 [45] | Inaccurate account documentation (missing or false forms) | A21 [15] | Referred or provided US taxpayers with the names of outside services providers who could create structures or assisted them with creating structures |
A7 [22] | Accounts in the name of non-US-persons that were owned by US taxpayers | A22 [1] | Remove bank letterhead from account statements |
A8 [56] | Accounts in the name of foundations/companies with US residents as their beneficial owners | A23 [5] | Transmitting undeclared assets to a US taxpayer client in a hidden manner (for instance by delivering cash in person) |
A9 [4] | Advise clients to conceal their US nexuses from bank documentation or avoid bringing account information to the US | A24 [9] | e-banking, retail, and private banking services for US clients |
A10 [9] | Issuing checks drawn on the client’s/customer’s account or wire transfers | A25 [6] | Transfer of assets from US-related accounts through non-US accounts en route to accounts at unaffiliated banks to conceal the US relatedness of these accounts |
A11 [3] | Issuing checks drawn on one of the bank’s accounts | A26 [2] | Discussing Swiss banking secrecy with US taxpayer clients |
A12 [45] | Opening accounts for persons that left other banking being investigated by the DOJ or have been exited or left during the financial crisis | A27 [1] | Failing to adopt an account-closing protocol |
A13 [1] | Destroying correspondence upon request | A28 [1] | Transitory account |
A14 [10] | Concealment of communications through prepaid mobile phones, fax, or personal email or communication by confidential means in general | A29 [1] | Advisory or booking center |
A15 [5] | No registration of US taxpayer clients as US persons in the bank’s IT system | A30 [24] | Structured payments |