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.
But non-Swiss banks should also take heed. They would be well-advised to pay close attention to the information that the Swiss banks are disclosing because, in all likelihood, the Justice Department’s aim is about to expand. And when it does, the department is likely to follow the flow of money from the Swiss banks to their non-Swiss counterparts.
