DOJ Announces Final Resolutions Under Its Groundbreaking Swiss Bank Program As Program Enters “Legacy” Phase

   On December 29, 2016, the Justice Department’s Tax Division announced that it had reached final resolutions with the remaining “Category 3 and 4” Swiss banks that had enrolled in the Swiss Bank Program. Originally unveiled in August 2013, the Swiss Bank Program provided a path for Swiss banks to resolve their potential criminal exposure under U.S. tax laws, and to cooperate in the Justice Department’s ongoing investigations of the use of foreign bank accounts by U.S. taxpayers to commit tax evasion.  The Swiss Bank Program also provided a mechanism for those Swiss banks that were not engaged in wrongful acts but nonetheless wanted a resolution of their status.