The IRS and the Department of Justice have been on a long campaign of trying to get banks to turn over information on U.S. accountholders. A program called the Swiss Bank Program divided financial institutions into four different categories, with Category 3 and 4 banks in compliance with U.S. tax laws and Category 1 and 2 banks suspected of aiding U.S. citizens in evading tax obligations.

The IRS rewards whistleblowers who come forward and report attempts to evade taxes.  One whistleblower received a record amount of money for reporting on the activities of UBS AG in facilitating tax evasion. That whistleblower is now assisting France with its own investigation into UBS and the testimony he provides is expected to significantly increase pressure on the bank.

Wegelin & Co. was indicted in 2012, along with three of its client advisors, Urs Frei, Michael Berlinka, and Roger Keller. Recently, in February of 2015, the U.S. government filed a superseding indictment. Wegelin & Co. was removed from the indictment because the bank has pled guilty, paid $74 million in fines and ceased operations.  Additionally, charges were limited against Keller, who has been arrested in Germany and is awaiting extradition. No change was made to the charges against the other two client advisors.

Authorities are already convinced of the need to aggressively go after investors who may be hiding money offshore in order to avoid full compliance with tax obligations.  Estimates indicate that around $7.6 trillion in wealth is held in offshore accounts, depriving governments worldwide of around $200 billion in unpaid income tax revenue. 

UBS Bank has been hit hard by federal investigators in recent years. In 2009, the offshore bank settled claims of helping clients to evade IRS tax obligations, paying a penalty of $780 million.  The bank is now being investigated again, this time for allegedly marketing illegal investments to U.S. investors who wanted to hide the income they were earning from the Internal Revenue Service.