Recent discussions between the US and Switzerland have centered on a US tax dispute settlement program for category two, three, and four banks and the current US criminal investigations into category one banks that are domiciled in Switzerland. The category one banks are those that are subject to a US criminal investigation and are aiming to reach a Deferred Prosecution Agreement. Those who believe they may have committed an offence and are looking for non-prosecution agreement are category two. If a bank has not committed any offence it is in a position to apply to be in category three, while compliant banks with a local core of clients are in the fourth category.
Swiss banks are accused of helping US citizens to evade taxes through the use of undeclared bank accounts, often in the name of sham entities, where assets and income could be hidden from the US tax authorities. The accusations extend to actions such as destruction of bank records and evasion of disclosure requirements.
