NA VIGANT

GLOBAL INVESTIGATIONS & COMPLIANCE

FATCA Highlights
Do Swiss Banks Have Less Time to Comply with FATCA
than the Rest of the World?
The U.S. Department of Justice and Swiss Federal Department of
Finance Announce a Program for Swiss Banks to Avoid a U.S. Based
Prosecution for Tax Evasion
Released September 2013
Volume 10
By Ellen Zimiles, Richard Kondo, Jeffrey Locke and Courtland Hillman
DISPUTES & INVESTIGATIONS ECONOMICS FINANCIAL ADVISORY MANAGEMENT CONSULTING
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I. INTRODUCTION
A. Background
On 29 August 2013, the United States Department
of Justice ("U.S. DOJ") and the Swiss Federal Depart-
ment of Finance issued a joint statement announc-
ing a program (the "Program") , which will all ow
Swiss banks to potentially mitigate the risk of suffer-
ing criminal charges brought by the U.S. DOJ.
1
The
U.S. DOJ press release issued the same day as the
joint statement states that participating Swiss banks
will be required to:
2
1. Agree to pay substanti al penalties;
2. Make a complete disclosure of their cross-border
activities;
3. Provide detailed information on an account-by-
account basis for accounts in which U.S. taxpay-
ers have a direct or indirect interest;
4. Cooperate in treaty requests for account infor-
mation;
5. Provide detailed information as to other banks
that transferred funds into secret accounts or
that accepted funds when secret accounts were
closed and
6. Agree to close accounts of account holders who
fail to come into compliance with U.S. reporting.
3
The Program also accelerates the due dale for the
pre-existing account review proscribed under the
Agreement between the United Slates of Ameri ca
and Switzerland for Cooperation to Facilitate the
Implementati on of FATCA by one year or more. as
explained more fully below.
B. Essential Questions Posed to Swiss Banks by
the Program
The Program asks Swiss Banks to answer two impor-
tant questions very quickly:
1. Did the Swiss Bank commit a U.S. tax or monetary
transaction criminal off ense? and
2. How many U.S. Related Accounts did the Swiss
Bank maintain at different points in time?
The answers to these two questions will pose
more questions, but should also help drive next steps
such as:
1. Determining the Swiss Bank's status as a
Category 2, Category 3 or Category 4 Bank un-
der the Program;
2. Determining when to file a disclosure with the
U.S. DOJ;
3. Identifying an independent examiner and ensur-
ing the independent examiner will be approved
by the U.S. DOJ and
4. Developing a project plan to complete all rel-
evant analyses to meet the light deadlines out-
lined in the Program.
Below is a high-level summary of the Program to as-
sist Swiss Banks with their assessment of the Program.
II. THE PROGRAM
The outline for the Program is 11 pages long and should
be read very carefully. Below we discuss how a Swiss
Bank determines ( 1) its category, (2) what information
needs to be provided to the U.S. DOJ should a Swiss
t Press Umted States and Swttzerta:,d nue 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 ce gov op pr 201liAuousL1J.lil.c975.htnl
2 !Jr1der 'he Program the tenn s..,,ss Sank s N.U\ L"lo term sw ss I= nne1a.i nst.:':Jt n .. sed n the ex..::ept !n.tt hal exclude an, niiHtment EntJt( or Spec1fted nsurance Comp:tny
U't.J! does not independentry meet tne defin,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
!'lrt:J iw'Hw JUSttce so 8592013.8291042132l5599 pa!
3 !)ress supra note t
.! See A;reement betv.:'!ef' Un1te-d Sute' of _,m.:r ea a.nd Sw.tzerl3nd
1
orCooperatio to l.ta!ethe mp emef'lta
1
l0n f !.1 Febfuary 1 13 ere natter J S Sw n FATCAAQreementj 3Va0Jble at bttp wNW
resourcecenter tax-poliC'/ pdf
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1 I FATCA HIGHLIGHTS I VOLUME 10 /\
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Bank participate in the Program. (3} how the Program's
due diligence requirements overlap with FA TCA com-
pliance, (4) the role of the independent examiner and
(5) potential penalties for Category 2 Banks.
5
A. Category of Swiss Bank
As an initial step, the Program requests Swiss banks
define themselves as a Category 1 Bank. a Catego-
ry 2 Bank. a Category 3 Bank. or a Category 4 Bank.
1. Category 1 Bank
A Category 1 Bank is any Swiss Bank for which
the Tax Division of the U.S. DOJ has authorized a
criminal investigation concerning its operations.
The Program is not available to Category 1
Banks. The U.S. DOJ is currently investigating the
Swiss-based activities of 14 financial institutions.
7
2. Category 2 Bank
A Category 2 Bank is any Swiss Bank that is not a
Category 1 Bank (not already under criminal in-
vestigation) and also not a Category 4 Bank (see
below) .
8
A Category 2 Bank is a bank that has
reason to believe it may have committed tax-
related offenses or monetary transaction offens-
es in connection with undeclared U.S. accounts
held by the Swiss Bank.
9
A Category 2 Bank may
request a non-prosecution agreement ("NPA")
from the U.S. DOJ. '
0
The request must be made
by 31 December 2013.
11
3. Category 3 Bank
A Category 3 Bank is any Swiss Bank that is not
a Category 1 Bank (not already under criminal
investigation) and also not a Category 4 Bank
(see below).
12
A Category 3 Bank also has not
committed any tax-related offenses or monetary
transaction offenses in connection with unde-
clared U.S. accounts held by the Swiss Bank.
13
A
Category 3 Bank may request a non-target letter
from the U.S. DOJ.
14
11 must request the non-target
letter no earlier than 1 July 2014 and no later than
31 October 201 4. 's
4. Category 4 Bank
A Category 4 Bank is any Swiss Bank that is not a
Category 1 Bank (not already under criminal in-
vestigation} and is a "Deemed Compliant Finan-
cial Institution" qualified as a "Financial Institution
with Local Client Base" as of 31 December 2009
and 29 August 2013 under the FATCA Agree-
ment.'6 A Category 4 Bank may request a non-
target letter no earlier than 1 July 2014 and no
later than 31 October 2014Y
A Financial Institution with a Local Client Base.
according to the FATCA Agreement. must meet
a handful of requirements including:
a. The Swiss Bank must have no fixed place of
business outside Switzerland;
5 Annexed hereto as an ''a summary chart companng the roqu1remonts for Category 2. Category land Catogory -1 Swss B:tnk'
6 The Program. supra note 2. pt I A
1 Release. supra note 1
8 The Program supra note 2. pt.ll A. 12
9 Th& Pro;ram. supra note 2. Pt II A J.
10 The Program !upra note 2. pt II A
11 The Program s1.1pra note 2. pt. II 8
12 The Program. supra note 2. pt Ill A t-2
13 The Program !upra no1e pt.111AJ.
14 The Program, 5upra note 2. pt. HI.A
15 Tho Program. supra note 2. pt.lll 8
16 The Program. supra note 2 pt.IV.A 2
t7 The orogram supra note 2 pt IV 8
2 I FATCA HIGHLIGHTS I VOLUME 10 /\
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b. The Swiss Bonk must not solicit account holders
outside of Switzerland and
c. At least 98 percent of the accounts by value
provided by the Swiss Bonk must be held by
residents (including residents that ore entities)
of Switzerland or a member State of the Euro-
pean Union.
18
B. Initial Disclosure to the U.S. DOJ
To enter into the Program, the Swiss Bonk must
request permission from the U.S. DOJ. As stated
above, Category 2 Bonks will request a non-prose-
cution agreement while Category 3 and Category 4
Bonks will request a non-target letter. At the time of
request, assuming the Swiss Bonk wonts to enter into
the Program, the Swiss Bonk must also supply addi-
tional information to the U.S. DOJ, as outlined below.
1. Category 2 Bonks
Category 2 Bonks requesting a NPA must express
its intent by 31 December 2013. In addition, the
letter 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 terms
of the non-prosecution agreement as set out
in this program. including all records that may
be sought by treaty requests and
d. Slate that the Swiss Bonk will waive any de-
fense based on the statute of limitations for
the period from the dote of the announce-
ment of this Program to the issuance of a non-
prosecution agreement or deferred prosecu-
tion ogreement.
19
Furthermore, prior to executing a non-prosecu-
tion agreement, the Swiss Bonk must identify:
a. How the cross-border business for U.S.
Related Accounts was structured, operated
and supervised:
b. The nome and function of the individuals
who structured, operated, or supervised the
business:
c. How the Swiss Bonk attracted and serviced
U.S. taxpayer account holders and
d. The total number of accounts and maximum
dollar value. in aggregate. for U.S. Related Ac-
counts for certain time periods.
20
The U.S. DOJ requires on in-person presentation
and documentation, supporting the disclosure of
a. through c. above, and retains the authority to
follow-up to request additional or clarifying infor-
motion.21
2. Category 3 and Category 4 Bonks
Category 3 Bonks and Category 4 Bonks request-
ing a non-forget letter must express their intent no
earlier than 1 July 2014 and no lofer than 31 Oc-
tober 2014. In addition the letter must:
a. Include a plan for complying with the require-
ments in the Program. within a reasonable
lime, but not to exceed 120 days from the
dole of the Iefier of intent:
b. Provide the identify and qualifications of the
independent 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 Institution WLth a Local Client Base
19 The Program. supra note 2, pt. II.B. 14.
20 The Program. supra note 2. pt. 11.0.1 d.ae
21 The Program. supra note 2. pt.ll 0.1.d. There are also addLtlonal tor the Sw1ss Bank after eecution of the non-pro5ecutlon agreement as outJmtd 1n pt II 0.2 or The Program
3 I FATCA HIGHLIGHTS I VOLUME 10 )\
c. State that the Swiss Bonk will maintain all re-
cords required for compliance wi th the terms
of the Program and
d. State that the Swiss Bank will waive any de-
fense based on the statute of limitations for
the period from the dote of the announce-
ment of this Program to the issuance of o non-
prosecution agreement or deferred prosecu-
tion ogreement.
22
C. The Program's Overlap with FA TCA 's Due Diligence
Procedures
The bulk of the analysis to be conducted by the
Swiss Bonk is driven by FATCA requirements. with
some significant changes. and the Program makes
reference to "FATCA" five times.
23
The overlap be-
tween FA TCA compliance and complying with the
terms of the Program cannot be overstated.
1. U.S. Related Accounts
The greatest overlap occurs in the definition of
u.s. Related Accounts. The Program defines o
U.S. Related Account as on
account which exceeded $50,000 in value
at any time during the Applicable Period.
as measured by the account balance on
the last day of each month during the Ap-
plicable Period, and as to which indicia
exists that o U.S. Person or Entity has or hod
a financial or beneficial interest in. owner-
ship of, or signatory authority ... over the ac-
count as determined by applying the due
diligence procedures applicable to "Lower
Value Accounts" in the FATCA Agreement.
Annex I. Part II. for accounts with $250.000
or less in value at all times during the Ap-
plicable Period. and by applying the due
diligence procedures applicable to "High-
Value Accounts" in the FATCA Agreement,
Annex I. Port II. for accounts with more
than $250,000 in value at any time during
the Applicable Period, notwithstanding the
amounts and dates set out in the FATCA
Agreement. Annex I. Port 11.
2
'
Annex I, Port II of the FATCA Agreement is gener-
ally referred to as the FATCA pre-existing individ-
ual account analysis. The U.S. DOJ appears to be
essentially asking Swiss Bonks to identify U.S. Re-
lated Accounts using FATCA 's due diligence pro-
cedures. subject to certain changes such as dol-
lor value thresholds. The U.S. DOJ is also asking for
this "FATCA-Iike" analysis to be done in less than
six months from the date of disclosure to the U.S.
DOJ assuming the independent examiner review
must also be completed within the six-month time
frame.
25
The identification of U.S. Related Accounts is
what the U.S. DOJ is seeking and is what the inde-
pendent examiner, explained more fully below.
is verifying. Specifically, o Category 2 Bank must
supply information to the U.S. DOJ relating to the
total number and maximum value. in aggregate.
of U.S. Related Accounts that existed or were
opened at certain times. among other things.
26
Additionally, a Category 3 Bonk must have the
independent examiner verify the percentage
of the Swiss Bank's account holdings and assets
under management that are U.S. Related Ac-
22 Tht req1.mements tor 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 a Category 4 Bank tt .almost entirely dnnn by a F'ATCA Agreement def:nct1on.
2.& The Program. tupra note 2 pt.l8.9 AdcMJonally1 for FATCAcompltancepurposes the dollar'IJJue threshold to determme whether .1n 11 a high-value account Is 51.000.000 While .n the Program that value IS
$250,000.
25 For ell ample, a CategorJ 2 Bank must compiV wtth the term ollhe Program In 120 days I rom cts letter of Intent and wll be .JIIowed a one time 60 day extension upon the showmg of good cause The Program supra note 2,
ptll B I
26 Tht Program. supra note 2. pt. II 0.1.e
4 I FATCA HIGHLIGHTS I VOLUME 10 I\
counls.
27
A Category 4 Bank must meet certain
tests including that 98% of its account holders are
residents of Switzerland or Member Slates of the
European Union.
28
2. FATCA's Due Diligence Procedures
Implementing FATCA 's due diligence procedures
and analyzing account holders will be lime con-
suming and lime is not afforded to Swiss Banks that
comply with the Program. In general. for lower value
accounts, Swiss Bank must search their electronic in-
formation 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 of
birth;
c. Current U.S. mailing or residence address (in-
cluding a U.S. post office box or a U.S. "in-
care-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 that
is the sole address the Swiss Bank has on file
for the account holder. In the case of a
"lower value account", an "in-care-of" ad-
dress outside the U.S. shall not be treated as
U.S. indicia.
29
27 The Program. supra pt. Ill E .I .
28 See th1 U.S SWiss FATCA Agreement. supra note 18 Annex II pt. II A 1.e
29 U.S SWISS FATCAAgreement. Annet I. pt 11.9. 1 ag
30 s .. US SWISs Annex I ptii.O
31 The Program. supra note 2. pt I.B 10.
For higher value accounts. the Swiss Banks must un-
dertake a review of certain paper records to search
for U.S. indicia as well as query the relationship man-
ager for knowledge of the account holder' s U.S. lax-
payer stalus.
30
Furthermore, if the Swiss Bank identi-
fies U.S. indicia it may provide the account holder
with 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 to
complete in a matter of months. By way of com-
parison, the FA TCA Agreement allows Swiss Banks
two years. beginning on 1 July 2014, to meet these
requirements and complete the necessary steps,
when the limeline outlined in IRS Notice 2013-43
is applied.
D. The Role of the Independent Examiner
The independent examiner must begin work soon
after the Swiss Bank determines its potential cate-
gory. including whether the scale is lipped to move
the Swiss Bank from a Category 3 Bank to a Cat-
egory 2 Bank, discloses its intent to the U.S. DOJ and
accounts for its U.S. Related Accounts. The Program
defines the independent examiner as "a qualified
attorney or accountant; the Tax Division [of the U.S.
DOJ] reserves the right to object to a particular at-
torney or accountant, but will not unreasonably
withhold approval."
3
'
Every Category 2. Category 3 and Category 4 Swiss
Bank that enters into the Program must retain an
independent examiner that is pre-approved by the
U.S. DOJ.
32
The role of the independent examiner is
dependent on the category of Swiss Bank.
32 See The Program. supra note 2, pt.11.8.3 (Category 2 Banks). See The Program. supra note 2, pt Ill B.J (Category 3 Banks}. See The Program, supra note 2, pt. IV.B.J (Category 4 Baoks).
5 I FATCA HIGHLIGHTS I VOLUME 10 /\
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1. The Role of the Independent Examiner for
Category 2 Banks
The lndependant Examiner must:
a. Identify the number of U.S. accounts closed
for the applicable period;
33
b. 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 the
relationship to the account of each such
U.S. person or entity or potential U.S. person
or entity;
iii. Whether the account was held in the name
of an individual or an entity;
iv. Whether the account held U.S. securities
during the Applicable Period;
v. The name and function of any relationship
manager, client advisor. asset manager, fi-
nancial advisor. trustee, fiduciary, nominee,
attorney, accountant. or other individual
or entity functioning in a similar capacity
known by the Bank to be affiliated with said
account at any time during the Applicable
Period;
vi. Information concerning the transfer of
funds into and out of the account during
the Applicable Period on a monthly basis.
c. Confirmation that the due diligence stan-
dards set out in the Program were applied in
collecting the relevant information.
34
2. The Role of the Independent Examiner for
Category 3 Banks
The Program dictates that the independent exam-
iner carry out an internal investigation for Category
3 Banks. AI the end of the internal investigation, the
independent 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 Applicable
Period, accompanied by a description of the
compliance program; and
c. Provide the U.S. DOJ with a report of the Inde-
pendent Examiner's internal investigation that
includes:
i. A list of wi tnesses and a summary of state-
ments;
ii. Identification of the files reviewed;
iii. Factual findings and
iv. Conclusions.
35
3. The Role of the Independent Examiner for
Category 4 Banks
For Category 4 Banks the independent examiner
must provide verification that the Swiss Bank qualified
as a Financial Institution with a Local Client Base.
36
4. Selection of the Independent Examiner
The independent examiner plays a critical role in
the Program by verifying relevant information based
on the category of Swiss Bank. The independent
33 Th Applicable Penod means the penod betwetn 1 AugU11 2008 and ether (a) the later of 31 December 2014 or the effectJve d;ne of an FFI A;reement (for FAT CA. eompiance ourposes) or
(b) the date of the nonprose-cuuon agreement or nontargilt letter. tf that date s ear etthan 31 Oecl!mber 2014 tnciUSIVe The Program. supn note 2 pt I B 6
34 The Program. supra note 2. pt 11.0 2.e
)5 The Progr.am. supra noce2. pt.III.E 13
36 The Program. supra n o t e ~ pt.IV.C 1
6 I FATCA HIGHLIGHTS I VOLUME 10 I\
examiner should hove the specialized experience and qualifications necessary to conduct 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 and
g. Experience working as monitors of corporate entities.
E. Penalties
1. Category 2 Bonk Penalties
The U.S. DOJ called the penalties "substantial" in its press releose.
3
' In general. the penalty is calculated by a per-
centage of aggregate value of U.S. Related Accounts opened or maintained by the Swiss Bonk at given points in
time. as outlined below:
38
Applicable Time Frame PenaHy
As of 1 August 2008 20% of I he maximum oggregole value of all such accounts
that existed as of 1 August 2008
Between 1 August 2008 and 28 February 2009 30% of the..moximum aggregate value of all such accounts
opened belween 1 August 2008 through 28 February 2009
After 28 February 2009 50% of the maximum aggregate amount of all such
accounts opened otter 28 February 2009
2. The Penally "Set-Off" Provision
The maximum dollar value of the aggregated U.S. accounts may be reduced by the dollar value of each account
that the Swiss Bonk con demonstrate was not on undeclared account. This means that the account was disclosed
by the Swiss Bonk to the United Stoles Internal Revenue Service ("IRS") or was disclosed to the IRS by the account
holder following notification by the Swiss Bonk of a voluntary disclosure program and before the execution of a
NPA.
39
This "set-off" provision could set at odds the Swiss Bonk and the account holder- it is in the financial interest of
the Swiss Bonk to hove their U.S. taxpayer account holders voluntarily disclose the account.
J7 Prtn R tase. supr.t note
l8 The Program. supra nato 7 pi II H l 1
19 The Proo am. pra n<>te 7 pi I H
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7 I FATCA HIGHLIGHTS I VOLUME 10 A
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Ill. CONCLUSION
It is obvious the pressure of U.S. criminal tax enforcement on Swiss Banks was ratcheted up with the announcement of the
Program and there is no reason to believe the pressure valve will be released anytime soon. Swiss Banks should begin the
assessment of the Program to quickly determine if the Swiss Bonk will participate and what a project plan that meets the
U.S. DOJ's expectations will look like. Furthermore, not participating in the Program could hove more draconian penalties
than those announced by the U.S. DOJ.
Description Category 1 Category 2 Category 3 Category4
Excluded from the Program Yes No No No
Ability to Participate in the Program N/A Yes Yes Yes
Reason to Believe Committed Tax Offense N/A Yes No No
1 July2014- 1 July 201 4-
Initial Disclosure Due Date N/A 31 Dec 2013 31 October 31 October
2014 2014
120 days
from the letter 120 days 120 days
Due Date for FATCA-Iike Due Diligence to of intent+ from the letter from the letter
N/A
Identity U.S. Related Accounts a potential 60 of intent of intent
day extension (or 4 months). (or 4 months).
(or 4-6 months).
Use of Pre-Approved Independent Examiner N/A Yes Yes Yes
Comply with Plan within 120 Days of
Disclosure letter
N/A Yes Yes Yes
Necessity to Identity U.S. Related Accounts N/A Yes Yes Yes
Applicable Penalties under the Program N/A Yes No No
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8 I FATCA HIGHLIGHTS I VOLUME 10 /\
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ABOUT NAVIGANT'S
GLOBAL INVESTIGATIONS &
COMPLIANCE PRACTICE
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tice brings critical expertise and resources to clients to assist
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..
CONTACTS
Ellen Zimiles
Managing Director
+ 1.2 12.554.2602
ellen.zimiles a naviganl.com
Ri chard Kondo
Director FATCA Task Force Leader
+ 1 212.554.2698
richard.kando Q'navigant .com
Jeffrey Locke
Director. FA TCA Task Force Leader
+ 1 .212.554.2694
jeffrey.locke o navigan l .com
Salvatore LaScala
Managing Director
+1.212.554.2611
salvatore.lascala g navigant.com
Bernard Factor
Director
+44 (0) 20 7469 1116
bernard .factor <inavigant.com
Jon Harvey
Director
+44 0) 20 7015 2373
jon .harvey a navigan I .com
David Brown
Director Business Development
+1.4 16.777.2438
dovid.brown o noviganl.com
DISPUTES & INVESTIGATIONS ECONOMICS FINANCIAL ADVISORY MANAGEMENT CONSULTING
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9 I FATCA HIGHLIGHTS I VOLUME 10 /\
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