The first non-prosecution agreement signals expanded US tax enforcement opportunities at home and abroad.

Since that presentation, the US Department of Justice (DOJ) has announced the first Non-Prosecution Agreement (NPA) with BSI, SA, (BSI) one of Switzerland’s largest banks, under its Swiss Bank Program.

The NPA illuminates the Swiss banking community’s struggle to comply with US tax laws.

The agreement reveals the machinations of US clients and a web of facilitators, and directs US authorities to other financial jurisdictions throughout the world that transferred funds into secret accounts or accepted the funds of US account holders fleeing Switzerland after 2008.

The DOJ and the Internal Revenue Service (IRS) have vowed to “follow the money” in pursuit of additional investigations of both banks and individuals.

To download the briefing on NPAs, please click here.