On 6 January 2016, the DoJ announced that it had signed a nonprosecution agreement (NPA) with Union Bancaire Privée (UBP), pursuant to the terms of the Swiss Bank Programme.

The Programme provides a path for Swiss banks to resolve potential U.S. tax-related criminal liabilities if such banks had come forward in 2013 with reason to believe that they had committed criminal offences in connection with undeclared Swiss accounts belonging to U.S. taxpayers.

The NPA requires UBP to:

  • pay a penalty of $187 million; and
  • voluntarily disclose information relating to its activities in designing structures to assist tax evasion.