Daly said the UBS accounts are leading to bankers who directed U.S. customers to smaller banks. "We see those people as extremely culpable," he said.
Foreign bankers also are more willing to come forward with information on their clients to protect themselves. Many of these bankers can't leave Switzerland or Liechtenstein because they know they could be arrested.
"Your former bankers, your former asset managers, your former fiduciaries are tired of being captive in their own country," Daly said. "And that's important because there are thousands of people out there who are recalcitrant."