The Tide is Coming in on Offshore Account Enforcement: The Swiss Bank Program and Enforcement of the Foreign Bank Account Report

Attorney Bradley Russell contributed an article to The Banking Law Journal, “The Tide Is Coming In on Offshore Account Enforcement: The Swiss Bank Program and Enforcement of the Foreign Bank Account Report,” on September 8, 2015. The article discussed the Department of Justice’s Swiss Bank Program, wherein Swiss banks may provide their American depositors’ account information to U.S. authorities under the U.S.-Swiss tax treaty. Russell provides insight on the Bank Secrecy Act, the Foreign Bank Account Report, recent enforcement actions and the likelihood that the Swiss Bank Program will result in increased civil and criminal enforcement actions against Americans with undeclared offshore accounts.