Category 4 is reserved for banks with local customers, as defined by FATCA. The DoJ has collected and published relevant practices involving banks. We identify a small number of such activities that seem to help explain some of the discrepancies in fines. The activities we identify are related to the fact that clients can withdraw cash anonymously or help them hide their accounts from U.S. tax authorities. These banks will seek non-prosecution agreements (APNs). Finally, we collected balance sheet data for as many banks as possible for 2013. In particular, we collected the balance sheet size, capital, revenues and profits of 60 banks. For 18 banks, all of which specialize in Private Banking Footnote 7, we do not have access to business reports. More generally, the programme has paved the way for the Swiss banking secrecy case with regard to a large number of legal systems. Switzerland has since today signed automatic exchange agreements on foreign customers of Swiss banks with 41 countries.

The Swiss banking sector has been firmly transformed as a result of this programme. “In today`s agreement, UBP acknowledges that there were additional U.S. accounts that it knew or should have known about, but that were not disclosed,” the DoJ said, adding that the bank had “fully cooperated” after the discovery of the additional accounts. “This agreement reflects our obligation to ensure that foreign banks that participated in the Swiss Bank program fully comply with their obligations to disclose accounts over which U.S. taxpayers have direct or indirect interests,” said Richard E. Zuckerman, Assistant Attorney General of the Department of Justice. “If an organization or organization makes false, incomplete or misleading statements to the unit, the department will hold those individuals or entities to account.” Switzerland and the United States of America sign a joint declaration to settle a long-standing tax dispute between Swiss banks and the United States. At the time, the DoJ had gathered evidence that several Swiss banks had systematically helped U.S. tax evaders. Several Swiss banks have already been the subject of a criminal investigation by the DoJ.

The largest of these banks, UBS, had moved in 2009 and obtained a deferred law enforcement agreement (DPA) in exchange for full cooperation with the DoJ, including the identification of the names of clients and employees, and a fine of $780 million. A bank (Wegelin) collapsed in 2012 following the conflict with the DoJ. Six major banks (Credit Suisse, Bank Julius Baer, Pictet, HSBC, Zurich Cantonal Bank and Basel Cantonal Bank) as well as eight small banks had also been penalised, but had not yet settled their accounts at the time of the programme`s creation.