On January 3, 2012, the U.S. Attorney’s Office for the Southern District of New York charged three Swiss bankers with hiding more than $1.2 billion in U.S. taxpayer accounts from the IRS.  The announcement was made by Preet Bharar, the Manhattan U.S. Attorney.

Michael Berlinka, Urs Frei And Roger Keller allegedly conspired with some U.S. taxpayers and others to hide Swiss bank accounts and the income generated from them while working as client advisers for a Swiss bank.  The three allegedly worked on dozens of undeclared bank accounts in 2008 and 2009 in an effort to pick up business lost by UBS and another Swiss bank, following the reports that the IRS is investigating UBS.

The three bankers allegedly helped U.S. clients open using sham corporation names in other countries as well as used code names and numbers on undeclared accounts to minimize references to the clients’ actual names. In addition, they allegedly made sure that any mail related to the accounts wasn’t sent to clients at their U.S. addresses and communicated using their personal email accounts to avoid detection, among other allegations, according to the release.

You an read the full text of the U.S. Attorney’s release here.

This case continues the trend that we’ve been covering and discussing lately.  The IRS and the Department of Justice will continue prosecution and audits of the offshore accounts.  Information gathered by the governments from the 2009 and 2011 Offshore Voluntary Disclosure programs will assist the IRS and DOJ to identify potential targets and areas of non-compliance.

Our attorneys will continue assisting taxpayers with foreign account compliance issues.