Disclosure of actual client names and account data, which American authorities have been aggressively seeking, would take place under a taxation treaty between the two countries that the American side has not yet ratified. Banks under criminal scrutiny that agree to cooperate with the decision could still face deferred-prosecution or nonprosecution agreements, a lesser punishment than indictment.
American clients whose names are handed over by Swiss banks but who have not voluntarily disclosed hidden accounts to the Internal Revenue Service would probably face criminal tax-evasion charges, lawyers said. Dozens of Americans have been indicted or charged in recent years for failing to disclose their accounts.
The decision also requires Swiss banks that cooperate with the Justice Department to protect their bankers and employees from, among other things, being fired for cooperating. American authorities have indicted more than two dozen Swiss bankers, lawyers and financial advisers in recent years.
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The New York Times