The Swiss Bank Program lets banks pay penalties and enter into non-prosecution agreements to avoid criminal charges for helping to facilitate tax evasion.  The banks can't just pay the penalty to participate -- they also have to provide information to the Department of Justice about account holders and their tax evasion activities. 

The Internal Revenue Service has the ability to move forward with civil and criminal actions against suspected tax evaders.  The Department of Justice also has a tax division, which works to prosecute individuals and businesses that are in violation of tax law.  Recently, the Acting Assistant Attorney General (AAG) of the Tax Division of the United States Department of Justice gave a keynote address at a continuing legal education conference held by the American Law Institute. At the keynote address, AAG Caroline Ciraolo outlined some of the Justice Department's priorities.

U.S. authorities are trying to find offshore funds that taxes may not have been paid on.  There are many different initiatives underway aimed at identifying people who have accounts offshore but who have not declared those accounts or paid income taxes on money earned.  One of the initiatives, the Swiss Bank Program, encourages banks to come forward and turn their customers in, in exchange for the bank reducing its own penalties. Banks have increasingly been taking advantage of this option, at the expense of foreign accountholders. Now, another Swiss bank has provided information and agreed to cooperate with U.S. authorities on investigations into tax evasion.

The United States government requires U.S. citizens to report all of their offshore investments and accounts, even when citizens live abroad and have accounts in the location where they reside.  Annual reports of offshore accounts must be filed according to the requirements set forth in the Foreign Account Tax Compliance Act (FATCA).  To ensure no accounts slip through the cracks and that the government is aware of all accounts owned by U.S. citizens, the government has also been moving forward with establishing intergovernmental agreements for the exchange of information under FATCA.

There is currently an amnesty program allowing offshore banks to come forward and report their involvement in helping U.S. accountholders to evade tax obligations. There is also an amnesty program allowing individuals to come forward, report their own failures to report offshore accounts and pay a penalty.