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Financial institutions outside Switzerland may be tempted to think that the U.S. Department of Justice’s focus and pressure on Swiss banks in recent years leaves them in the clear. And, indeed, the DOJ has had great success in targeting these institutions far from U.S. shores. It has levied monetary penalties exceeding $3.3 billion to resolve criminal charges against two big Swiss banks, and has created a voluntary disclosure program that has so far attracted participation from more than 100.

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