US-Swiss voluntary disclosure programme: deadlines are looming — Swiss banks need not panic, but must act swiftly and thoughtfully
The recently announced voluntary bank disclosure programme between Switzerland and the US offers worried Swiss banks the possibility of peace of mind from future prosecution. The question now confronting Swiss banks is whether to take advantage of this programme and, if so, how best to enter the programme.
While these decisions are, of course, extremely important, Swiss banks should not necessarily be feeling a sense of panic or dread. Department of Justice internal guidelines discourage corporate prosecutions where a relatively low-level employee was involved in isolated or discrete transgressions. The department’s own policies dictate that it considers a variety of factors before determining to bring a prosecution in such instances…
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