On August 29, the DOJ announced a program to encourage Swiss banks to cooperate in its ongoing efforts to prosecute offshore tax evasion.  The program—which, according to a joint statement with the Swiss Federal Department of Finance, Switzerland will encourage Swiss banks to consider participating in—requires, among other things, Swiss banks to make significant disclosures to the DOJ about cross-border activities and accounts that affect U.S. taxpayers in exchange for non-prosecution agreements or non-target letters.