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NA VIGANTGLOBAL INVESTIGATIONS & COMPLIANCE

FATCA HighlightsDo Swiss Banks Have Less Time to Comply with FATCAthan the Rest of the World?The U.S. Department of Justice and Swiss Federal Department ofFinance Announce a Program for Swiss Banks to Avoid a U.S. BasedProsecution for Tax EvasionReleased September 2013Volume 10By Ellen Zimiles , Richard Kondo, Jeffrey Locke and Courtland Hillman

DISPUTES & INVESTIGATIONS ECONOMICS FINANCIAL ADVISORY MANAGEMENT CONSULTING


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I. INTRODUCTIONA. Background

On 29 August 2013, the United States Departmen tof Justice ("U.S. DOJ") and the Swiss Federal Department of Finance issued a joint statement announcing a program (the "Program"), which will a llowSw iss banks to potentially mitigate the risk of su ffering crimina l charges brought by the U.S. DOJ.1 TheU.S. DOJ press release issued the same da y as thejoint sta tement states that participating Sw iss banksw ill be required to:21. Agree to pay substan tial penalties;2. Make a comple te disclosure o f their cross-border

ac tivities ;3. Provide detailed information on an account-by

account basis for ac counts in which U.S. taxpayers have a direc t or indirect interest;

4. Cooperate in trea ty requests for account information;

5. Provide detailed information as to other bankstha t trans ferred funds into secret ac counts orthat accepted funds when secret accoun ts we reclosed and

6. Agree to close accoun ts of account holderswhofail to come into compliance with U.S. reporting .3

The Program also accelerates the due dale for thepre-existing account review proscribed under theAgreement between the Un ited Slates of Americaand Switzerland for Cooperation to Facilitate theImp lementa tion of FATCA by one year or more. asexplained more fully below.

B. Es sen tial Questions Posed to Sw iss Banks bythe ProgramThe Program asks Swiss Banks to answer two important questions very quickly:1. Did the Sw iss Bank commit a U.S. tax or mone ta ry

transaction criminal offense? and2. How many U.S. Related Accounts did the Swiss

Bank maintain at different points in time?The answers to these two questions will posemore questions, bu t should also help drive next stepssuch as :1. Determining the Swiss Bank's statusas a

Category 2, Ca tegory 3 or Category 4 Bank under the Program;

2. Determining when to file a disclosure with theU.S. DOJ;

3. Identifying an independent examiner and ensur-ing the independent examiner will be approvedby the U.S. DOJ and

4. Developing a project plan to comple te all relevant analyses to meet the ligh t deadlines outlined in the Program.

Be low is a high-level summary o f the Program to assist Sw iss Banks with their assessment of the Program.

II . THE PROGRAMThe outline for the Prog ram is 11 pages long and shouldbe read very carefully. Be low we discuss how a Sw issBank de termines (1) its category, (2) what informationneeds to be prov ided to the U.S. DOJ should a Swiss

t Press ~ e l e a s e Umted States and Swttzerta:,d nu e Jamt Statt!me'"t Regaru ng Ta-. Evas n nvest1g;:n on iHE ..J S Department ...usce A:1g 29 2013) h:tp rw.v.._ tust cegov op pr 201liAuousL1J.lil.c975.htnl2 !Jr1der 'he Program the tenn s..,,ss Sank s y ~ o r . y m o u s N.U\ L"lo term sw ss I= nne1a.i nst.:':Jt n ..sed n the ~ A T C A A . g r t ~ ' : n e n l ex..::ept !n.tt hal exclude an, niiHtmentEntJt( or Spec1fted nsurance Comp:tny

U't.J! does not independentrymeet tnedefin,tJon of Custod1at Ins! tutton or Oepos1tory nsltuton Program tor Ncn-Prose-cutton Agreements or Non-T:Jrget tett rdcr Swfss Banks Pt I B 4 (heret.,atter ;M r o g ~ a m )!'lrt:J iw'Hw JUSttce g o o ~ so p a ~ r e s o u r c e s . 8592013.8291042132l5599 pa!

3 !)ress q e ~ e a s e . supra note t.! See A;reement betv.:'!ef' ~ o o e Un1te-d Sute' of _,m.:r ea a.nd Sw.tzerl3nd 1orCooperatio to a c : i l.ta!ethe mp emef'lta1l0n f !.1 Febfuary 1 13 ere natter J S Sw n FATCAAQreementj 3Va0Jble at bttp wNW

~ e a s u r y . g o " resourcecenter tax-poliC'/ t t & a t ! & S . : O o c u m e r : t ~ ~ . A T C A A g r l ! e m r . I S ~ ' t z e r l a o d l - l . $ - 2 0 1 3 pdf

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Bank participate in the Program. (3} how the Program'sdue diligence requirements overlap with FATCA com-pliance, (4) the role of the independent examiner and(5) potential penalties for Category 2 Banks .5A. Category of Swiss Bank

As an initial step, the Program requests Swiss banksdefine themselves as a Category 1Bank. a Catego-ry 2 Bank. a Category 3 Bank. or a Category 4 Bank.1. Category 1Bank

A Category 1 Bank is any Swiss Bank for whichthe Tax Division of the U.S. DOJ has authorized acriminal investigation concerning its operations.The Program is not available to Category 1Banks. The U.S. DOJ is currently investigating theSwiss-based activities of 14 financial institutions.7

2. Category 2 BankA Category 2 Bank is any Swiss Bank that is not aCategory 1 Bank (not already under criminal investigation) and also not a Category 4 Bank (seebelow) .8 A Category 2 Bank is a bank that hasreason to believe it may have committed taxrelated offenses or monetary transaction offenses in connection with undeclared U.S. accountsheld by the Swiss Bank.9 A Category 2 Bank mayrequest a non-prosecution agreement ("NPA")from the U.S. DOJ. '0 The request must be madeby 31 December 2013.11

3. Category 3 BankA Category 3 Bank is any Swiss Bank that is nota Category 1 Bank (not already under criminalinvestigation) and also not a Category 4 Bank(see below). 12 A Category 3 Bank also has notcommitted any tax-related offenses or monetarytransaction offenses in connection with undeclared U.S. accounts held by the Swiss Bank.13 ACategory 3 Bank may request a nontarget letterfrom the U.S. DOJ.14 11 must request the non-targetletter no earlier than 1 July 2014 and no later than31 October 201 4. 's

4. Category 4 BankA Category 4 Bank is any Swiss Bank that is not aCategory 1 Bank (not already under criminal investigation} and is a "Deemed Compliant Financial Institution" qualified as a "Financial Institutionwith Local Client Base" as of 31 December 2009and 29 August 2013 under the FATCA Agreement.'6 A Category 4 Bank may request a nontarget letter no earlier than 1 July 2014 and nolater than 31 October 2014YA Financial Institution with a Local Client Base .according to the FATCA Agreement. must meeta handful of requirements including:a . The Swiss Bank must have no fixed place of

business outside Switzerland;

5 Annexed hereto as an p p o n d 1 ~ '' a summary chart companng the roqu1remonts or Category 2. Category land Catogory -1 Swss B:tnk'6 The Program. supra note 2. pt I A1 Release. supra note 18 The Program supra note 2. pt.ll A. 129 Th& Pro;ram. supra note 2. Pt II AJ.10 The Program !upra note 2. pt II A11 The Program s1.1pra note 2. pt. II 812 The Program. supra note 2. pt Ill A t-213 The Program !upra no1e pt.111AJ.14 The Program, 5upra note 2. pt. HI.A15 Tho Program. supra note 2. pt.lll 816 The Program. supra note 2 pt.IV.A 2t7 The orogram supra note 2 pt IV 8

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b. The Swiss Bonk must not solicit account holdersoutside of Switzerland and

c. At least 98 percent of the accounts by valueprovided by the Swiss Bonk must be held byresidents (including residents that ore entities)of Switzerland or a member State of the European Union.18

B. Initial Disclosure to the U.S. DOJTo enter into the Program, the Swiss Bonk mustrequest permission from the U.S. DOJ. As statedabove, Category 2 Bonks will request a non-prosecution agreement while Category 3 and Category 4Bonks will request a non-target letter. At the time ofrequest, assuming the Swiss Bonk wonts to enter intothe Program, the Swiss Bonk must also supply additional information to the U.S. DOJ, as outlined below.1. Category 2 Bonks

Category 2 Bonks requesting a NPA must expressits ntent by 31 December 2013. In addition, theletter must:a. Include a plan for complying with the require

ments set out in the Program:b. Provide the identify and qualifications of the

Independent Examiner:c. Stole that the Swiss Bonk will maintain all re

cords required for compliance with the termsof the non-prosecution agreement as set outin this program. including all records that maybe sought by treaty requestsand

d. Slate that the Sw iss Bonk will waive any defense based on the statute of limitations forthe period from the dote of the announce-

ment of this Program to the issuance of a nonprosecution agreement or deferred prosecution ogreement.19

Furthermore, prior to executing a non-prosecution agreement, the Swiss Bonk must identify:a. How the cross-border business for U.S.

Related Accounts was structured, operatedand supervised:

b. The nome and function of the individualswho structured, operated, or supervised thebusiness:

c. How the Swiss Bonk attracted and servicedU.S. taxpayer account holders and

d. The total number of accounts and maximumdollar value. in aggregate. for U.S. Related Ac counts for certain time periods.20

The U.S. DOJ requires on in-person presentationand documentation, supporting the disclosure ofa. through c. above, an d retains the authority tofollow-up to request additional or clarifying informotion.21

2. Category 3 and Category 4 BonksCategory 3 Bonks and Category 4 Bonks requesting a non-forget letter must express their intent noearlier than 1 July 2014 and no lofer than 31 October 2014. In addition the letter must:a. Include a plan for complying with the require

ments in the Program. within a reasonablelime, but not to exceed 120 days from thedole of the Iefier of intent:

b. Provide the identify and qualifications of theindependent examiner;

t8 See the U.SSwlss FATCAAgreement. Annex II pt. II.A.t aJior the full requrrements that must be met to qualify a' a Financial Insti tution Wth aLocal Client Base19 The Program. supra note 2, pt. II.B.14.20 The Program. supra note 2. pt. 11.0.1 d.ae21 The Program. supra note 2pt.ll 0.1.d. There are also addLtlonal r e q u L r ~ m e n t s tor the Sw1ss Bank after eecution of the non-pro5ecutlon agreement as outJmtd 1n pt II 0.2 or The Program

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c. State that the Swiss Bonk will maintain all records required for compliance with the termsof the Program and

d. State that the Swiss Bank will waive any defense based on the statute of limitations forthe period from the dote of the announcement of this Program to the issuance of o nonprosecution agreement or deferred prosecution ogreement.22

C. The Program's Overlap with FATCA s Due DiligenceProceduresThe bulk of the analysis to be conducted by theSwiss Bonk is driven by FATCA requirements. withsome significant changes. and the Program makesreference to "FATCA " five times.23 The overlap between FATCA compliance and complying with theterms of the Program cannot be overstated.1. U.S. Related Accounts

The greatest overlap occurs in the definition ofu.s. Related Accounts. The Program defines oU.S. Re lated Account as on

account which exceeded $50 ,000 in va lueat any time during the Applicable Period.as measured by the account balance onthe last da y of each month during the Applicab le Period, and as to which indiciaexists that o U.S. Person or Entity has or hoda financial or beneficial interest in. ownership of, or signatory authority .. over the ac count as determined by applying the duediligence procedures applicable to "LowerValue Accounts" in the FATCA Agreement.

Annex I. Part II. for accounts with $250.000or less in value at all times during the Applicable Period. an d by applying the duediligence procedures applicable to "HighValue Accounts" in the FATCA Agreement,Annex I. Port II. for accounts with morethan $250,000 in value at any time duringthe Applicable Period, notwithstanding theamounts and dates set out in the FATCAAgreement. Annex I. Port 11. 2'

Annex I, Port II of the FATCA Agreement is generally referred to as the FATCA pre-existing individual account analysis. The U.S. DOJ appears to beessentially asking Swiss Bonks to identify U.S. Re-lated Accounts using FATCA s due diligence procedures. subjec t to certain changes such as dollor value thresholds. The U.S. DOJ is also asking forthis "FATCA-Iike" analysis to be done in less thansix months from the date of disclosure to the U.S.DOJ assuming the independent examiner reviewmust also be completed within the six-month timeframe.25The identification of U.S. Related Accounts iswhat the U.S. DOJ is seeking and is what the independent examiner, explained more fully below.is verifying. Specifically, o Category 2 Bank mustsupply information to the U.S. DOJ relating to thetotal number and maximum value. in aggregate.of U.S. Related Accounts that existed or wereopened at certain times. among other things.26Additionally, a Category 3 Bonk must have theindependent examiner verify the percentageof the Swiss Bank's account holdings and assetsunder management that are U.S. Related Ac-

22 Tht req 1mements tor C ~ e g o r y 3 and Category.& bank.! are denllcal Tht Program. supra note 2 ptlll.8.1-4 (C.ttegory 3) The Progr.1m, supra noto 2 pt. Ill B. 1-4 {Category 4)23 Indeed the deflncuon ot aCategory 4 Bank tt .almost entirely dnnn by a F'ATCA Agreement def:nct1on.2.& The Program. tup ra note 2 pt.l8.9 AdcMJonally1 for FATCAcompltancepurposes the dollar'IJJue threshold to determme whether .1n ~ c o u n t 11 ahigh-value account Is 51.000.000 While .n the Program that value IS

$250,000.25 For ellample, aCategorJ 2Bank must comp iV wtth the term ollhe Program In 120 days I om cs letter of Intent and wll be .JIIowed a one ime 60 day extension upon the showmg of good cause The Program supra note 2,

ptll B I26 Tht Program. supra note 2. pt. II 0.1.e

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counls.27 A Category 4 Bank must meet certaintests including that 98% of its account holders areresidents of Switzerland or Member Slates of theEuropean Union.28

2. FATCA's Due Diligence ProceduresImplementing FATCA s due diligence proceduresand analyzing account holders w ill be lime consuming and lime is not afforded to Swiss Banks thatcomply with the Program. In general. for lower valueaccounts, Swiss Bank must search their electronic information for U.S. indicia. The U.S. indicia are:

a. Identification of the account holder as a U.S.citizen or resident;

b. Unambiguous indication of a U.S. place ofbirth;

c. Current U.S. mailing or residence address (in cluding a U.S. post office box or a U.S. "incare-of" address);

d. Current U.S. telephone number;e. Standing instructions to transfer funds to an

account maintained in the U.S.f. Currently effective power of attorney or signa

lory authority granted to a person with a U.S.address or

g. An "in-care-of" or "hold mail" address thatis the sole address the Swiss Bank has on filefor the account holder. In the case of a"lower value account", an "in-care-of" address outside the U.S. shall not be treated asU.S. indicia.29

27 The Program. supra n o t e ~ pt. Ill E I .28 See th1 U.S SWiss FATCA Agreement. supra note 18 Annex IIpt. II A 1.e29 U.S SWISS FATCAAgreement.Annet I. pt 11.9. 1 ag30 s . US SWISs F A T C A A g r e e m t n ~ Annex I ptii.O31 The Program. supra note 2. pt .B 10.

For higher value accounts. the Swiss Banks must undertake a review of certain paper records to searchfor U.S. indicia as well as query the relationship manager for knowledge of the account holder's U.S. laxpayer stalus.30 Furthermore, if the Swiss Bank identifies U.S. indicia it may provide the account holderwith the opportunity to prove he or she is not a U.S.citizen or resident for lax purposes.This is a complex process with many moving parts tocomplete in a matter of months. By way of comparison, the FATCA Agreement allows Swiss Bankstwo years. beginning on 1 July 2014, to meet theserequirements and complete the necessary steps,when the limeline outlined in IRS Notice 2013-43is applied.

D. The Role of the Independent ExaminerThe independent examiner must begin work soonafter the Sw iss Bank determines its potential category. including whether the sca le is lipped to movethe Swiss Bank from a Category 3 Bank to a Category 2 Bank, discloses its intent to the U.S. DOJ andaccounts for its U.S. Related Accounts. The Programdefines the independent examiner as "a qualifiedattorney or accountant; the Tax Division [of the U.S.DOJ] reserves the right to object to a particular attorney or accountant, but will not unreasonablywithhold approval."3 'Every Category 2. Category 3 and Category 4 SwissBank that enters into the Program must retain anindependent examiner that is pre-approved by theU.S. DOJ .32 The role of the independent examiner isdependent on the category of Swiss Bank.

32 See The Program. supra note 2, pt.11.8.3 (Category 2Banks). See The Program. supra note 2, pt Ill B.J (Category 3Banks}. See The Program, supra note 2, pt. IV.B.J (Category 4 Baoks).

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1. The Role of the Independent Examiner forCategory 2 BanksThe lndependant Examiner must:a. Identify the number of U.S. accounts closed

for the applicable period;33b. For each account identified:

i. The maximum value, in dollars, of each ac-count. during the Applicable Period;

n. The number of U.S. persons or entities affili-ated or potentially affiliated with each ac-count, and further noting the nature of therelationship to the account of each suchU.S. pe rson or enti ty or potential U.S. personor entity;

iii. Whether the ac count was held in the nameof an individual or an entity;

iv. Whether the ac count held U.S. securitiesduring the Applicable Period;

v. The name and function of any relationshipmanager, client ad visor. asset manager , fi-nancial advisor. trustee, fiduciary, nominee,attorney, accountant. or other individualor entity functioning in a smilar capacityknown by the Bank to be affiliated with saidaccount at any time during the ApplicablePer iod;

vi. Information concerning the transfer offunds into and ou t of the account duringthe Applicable Period on a monthly basis.

c. Confirmation that the due diligence stan-dards set out in the Program we re applied inco llecting the relevant information.34

2. The Role of the Independent Examiner forCategory 3 BanksThe Program dictates that the independent exam-iner carry out an internal investigation for Category3 Banks. AI the end of the internal investigation, theindependent examiner must:

a. Verify the percentage of the Swiss Bank's ac-count holdings and assets under manage-ment that are from U.S.Related Accounts.

b. Verify the Swiss Bank had an effective com-pliance program throughout the ApplicablePeriod, accompanied by a description of thecompliance program; and

c. Provide the U.S . DOJ with a report of the Inde -pendent Examiner's internal investigation thatincludes:i. A list of wi tnesses and a summary of state-

ments;ii. Identifica tion of the files reviewed;iii. Factual findings andiv. Conclusions.35

3. The Role of the Independent Examiner forCategory 4 BanksFor Category 4 Banks the independent examinermust provide verification that the Swiss Bank qualifiedas a Financial Institution with a Loca l Client Base .36

4. Selection of the Independent ExaminerThe independent examiner plays a cr itical role inthe Program by verifying relevant information ba sedon the category of Swiss Bank. The independent

33 Th Applicable Penod means the penod betwetn 1AugU11 2008 and ether (a) the later of 31 December 2014 or the effectJved;ne of an FFI A;reement (for FATCA. eompiance ourposes) or(b) the date of the nonprose-cuuon agreementor nontargilt letter. tf that date s ear etthan 31 Oecl!mber 2014 tnciUSIVe The Program. supn note 2 pt I B6

34 The Program. supra note 2. pt 11.0 2.e)5 The Progr.am. supra noce2. pt.III.E 1336 The Program. supra n o t e ~ pt.IV.C 1

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examiner should hove the specialized experience and qualifications necessary to conduc t the review required.Relevant backgrounds and experience of on independent examiner could include:

a. Former IRS and U.S. DOJ officials;b. Former bonk compliance officers:c. Investigative personnel who understand how lox evasion could occur at the Swiss Bonk:d. Experience conducting independent, internal investigations for corporate clients:e. Experience implementing FATCA compliance programs;f. Experience implementing and updating anti-money laundering ("AML") programs for financial institutions andg. Experience working as monitors of corporate entities.

E. Penalties1. Category 2 Bonk Penalties

The U.S. DOJ called the pena lties "substantial" in its press re leose.3' In general. the penalty is ca lcula ted by a percentage of aggregate value of U.S. Related Accounts opened or maintained by the Swiss Bonk at given points intime. as outlined below:38

Applicable Time Frame PenaHyAs of 1August 2008 20% of I he maximum oggregole value of all such accounts

that existed as of 1 August 2008Between 1 August 2008 and 28 February 2009 30% of the..moximum aggregate value of all such accounts

opened belween 1August 2008 through 28 February 2009After 28 February 2009 50% of the maximum aggregate amount of all such

accounts opened otter 28 February 2009

2. The Penally "Set-Off" ProvisionThe maximum dollar value of the aggregated U.S. accounts ma y be reduced by the dollar value of each accountthat the Swiss Bonk con demonstrate was not on undeclared account. This means that the ac count was disclosedby the Swiss Bonk to the Un ited Stoles Internal Revenue Service ("IRS") or was disclosed to the IRS by the accountholder following notification by the Swiss Bonk of a voluntary disclosure program and before the execution of aNPA .39 This "set-off" provision could set at odds the Swiss Bonk and the account holder- it is in the financial interest ofthe Swiss Bonk to hove their U.S. taxpayer account holders voluntarily disclose the account.

J7 PrtnR tase. supr.t note l8 The Program. supra nato 7 pi II H l 119 The Proo am. pra nte7 pi I H

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Ill. CONCLUSIONIt is obvious the pressure of U.S. criminal tax enforcement on Swiss Banks was ratcheted up with the announcement of theProgram and there isno reason to believe the pressure valve will be released anytime soon. Swiss Banks should begin theassessment o f the Program to quickly de termine if the Swiss Bonk will participate and what a project plan that meets theU.S. DOJ's expectations will look like. Furthermore, not participating in the Program could hove more draconian penaltiesthan those announced by the U.S. DOJ .

Description Category 1 Category 2 Category 3 Category4Excluded from the Program Yes No No NoAbility to Participate in the Program N/A Yes Yes YesReason to Believe Committed Tax Offense N/A Yes No No

1 July2014- 1July 201 4-Initial Disclosure Due Date N/A 31 Dec 2013 31 Oc tober 31 Oc tober

2014 2014

120 daysfrom the letter 120 days 120 days

Due Date fo r FATCA-Iike Due Diligence to of inten t+ from the letter from the letterN/AIdentity U.S. Related Accounts a potential 60 of intent of intentda y extension (or 4 months). (or 4 months).

(or 4-6 months).

Use of Pre-Approved Independent Examiner N/A Yes Yes YesComply with Plan within 120 Days ofDisclosure letter N/A Yes Yes Yes

Necessity to Identity U.S. Related Accounts N/A Yes Yes YesApplicable Penalties under the Program N/A Yes No No

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ABOUT NAVIGANT'SGLOBAL INVESTIGATIONS &COMPLIANCE PRACTICENaviganl's Global Investigations & Compliance (GIC) prac-tice brings critical expertise and resources to clients to assistthem with identifying, assessing and managing the compli-ance and business risks related to financial economic crimes .money laundering. sanctions. bribery an d corruption matters.investigative due diligence. FATCA . monitoring and investi-gations related to fraud. waste and abuse.

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CONTACTSEllen Zim ilesManaging Director+ 1.2 12.554.2602ellen.zimiles a naviganl.comRichard KondoDirector FATCA Task Force Leader+ 1 212.554.2698richard.kando Q'navigant comJeffrey Lock eDirector. FATCA Task Force Leader+ 1 212.554.2694jeffrey.lockeonavigan .comSalvatore LaScalaManaging Director+ 1.2 12.554.2611salvatore.lascala g navigant.comBernard FactorDirector+44 (0) 20 7469 1116bernard factor


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