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A former UBS bank executive and a Swiss attorney were indicted Thursday on a fraud conspiracy charge for allegedly helping affluent Americans evade taxes by concealing their wealth in bank accounts named for untraceable foreign shell companies. The indictment tied Hansruedi Schumacher, who was UBS’ regional market manager for its North American operation, and Matthias Rickenbach, a lawyer based in Zurich with Rickenbach & Partner, to four Americans with UBS accounts. Three of them also had accounts with Neue Zürcher Bank, where Schumacher moved in 2002. Schumacher attracted UBS account holders to his new bank, where he headed private banking, with a promise of distancing themselves from the long arm of U.S. law, federal prosecutors charged. Unlike UBS, Neue Zürcher Bank had no U.S. operations and could not be pressured to disclose its clients’ identities. Jeffrey Chernick, a Stanfordville, N.Y., toy wholesaler who pleaded guilty to tax evasion last month for his hidden UBS accounts, was a client of the latest two people charged in a wide-ranging U.S. tax probe of concealed foreign assets. The indictment said three other UBS account holders had a similar relationship with Schumacher and Rickenbach. Their case was assigned to U.S. District Judge Daniel T.K. Hurley in West Palm Beach, Fla. The indictment came a day after the United States and Switzerland released details of a compromise in an Internal Revenue Services lawsuit filed in Miami against UBS to obtain the names of the bank’s U.S. customers. Under the agreement, UBS will hand over the names of about 4,450 account holders who allegedly hid assets at the bank. The IRS had been seeking 52,000 names, sparking an international tug-of-war over the limits of Swiss banking secrecy. Former UBS private banker Bradley Birkenfeld, who was critical in providing information to U.S. authorities about the bank’s operations in the United States, is set for sentencing Friday in Fort Lauderdale, Fla., for tax conspiracy. The two new Swiss defendants may be beyond the reach of U.S. law. Switzerland does not extradite Swiss nationals, but the two men could risk arrest by traveling to a third country. UBS executive Raoul Weil, who ran the bank’s cross-border operations, was indicted last November and is considered a fugitive by the Justice Department. Weil’s attorney, Aaron R. Marcu of Freshfields Bruckhaus Deringer in New York, issued a statement Wednesday calling for charges to be dismissed, calling Weil “an innocent victim of a political dispute.” The latest indictment indicates a determination to charge whoever can be linked to hidden, untaxed wealth and browbeat other scofflaws into coming forward. “American taxpayers who sought to avoid taxes by hiding their assets in Swiss accounts are on notice that this investigation continues,” said acting U.S. Attorney Jeffrey Sloman in Miami. IRS Commissioner Doug Shulman warned, “We’re in the early stages of our work to crack down on offshore tax evasion.”

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