Initial success of DOJ Swiss bank amnesty program creates greater urgency for US taxpayers.

On December 31, 2013, the window to apply for the US Department of Justice’s (DOJ) amnesty program closed for certain Swiss banks seeking non-prosecution agreements with respect to potential violations of US law in connection with undeclared US-related accounts. The DOJ recently announced that, before the window closed, it received letters of intent to participate from no fewer than 106 banks. By April 30, 2014 (unless a 60-day extension is granted), each participant bank will be required to provide the DOJ substantial amounts of information with respect to its cross-border business, US account holders and advisors affiliated with US-related accounts and to pay penalties tied to the balance of US-related accounts as we described in a previous Client Alert.