Credit Suisse Services AG pleaded guilty this week to conspiring to hide more than $4 billion from the Internal Revenue Service (IRS) in at least 475 offshore accounts.
The guilty plea is the culmination of a years-long investigation by U.S. law enforcement to uncover financial fraud and abuse. Pursuant to the guilty plea and the NPA, Credit Suisse Services AG will pay a total of $510,608,909 in penalties, restitution, forfeiture, and fines.
Credit Suisse Services AG entered into a non-prosecution agreement (NPA) with the Justice Department’s Tax Division and U.S. Attorney’s Office for the Eastern District of Virginia, in connection with U.S. Accounts booked at Credit Suisse AG Singapore.
Under the NPA, Credit Suisse Services AG agreed to cooperate with the Justice Department in ongoing investigations. It also agreed to pay significant monetary penalties for maintaining accounts in Singapore on behalf of U.S. taxpayers who were using offshore accounts to evade U.S. taxes and reporting requirements.
According to the court documents, from Jan. 1, 2010, and continuing until about July 2021, Credit Suisse conspired with employees, U.S. customers, and others to willfully aid U.S. customers in concealing their ownership and control of assets and funds held at the bank.
This enabled those U.S. customers to evade their U.S. tax obligations in several ways, including by opening and maintaining undeclared offshore accounts for U.S. taxpayers at Credit Suisse AG. The bank also provided a variety of offshore private banking services that assisted U.S. taxpayers in the concealment of their assets and income from the IRS. It also allowed for their continued failure to file FBARs.
In addition, the documents say that bankers at Credit Suisse falsified records, processed fictitious donation paperwork, and serviced more than $1 billion in accounts without documentation of tax compliance. In doing so, Credit Suisse AG committed new crimes, breaching its May 2014 plea agreement with the United States.
Then, between 2014 and June 2023, Credit Suisse AG Singapore held undeclared accounts for U.S. persons, which Credit Suisse AG Singapore knew or should have known were U.S., with total assets valued at over $2 billion.
Further, Credit Suisse AG Singapore failed to adequately identify the true beneficial owners of accounts and failed to conduct adequate inquiry about U.S. indicia in the accounts.
In 2023, during the post-merger of UBS AG Singapore and Credit Suisse AG Singapore, UBS became aware of accounts held at Credit Suisse AG Singapore that appeared to be undeclared U.S. accounts. UBS froze some of the accounts, voluntarily disclosed information about those identified accounts to the Justice Department and cooperated by undertaking an investigation into the identified accounts.
As part of the plea deal, Credit Suisse Services AG and, by extension, UBS AG, are required to cooperate fully with ongoing investigations and disclose any information it may later uncover regarding U.S.-related accounts.
Acting Deputy Assistant Attorney General Karen Kelly of the Justice Department’s Tax Division, U.S. Attorney Erik Siebert for the Eastern District of Virginia, and Chief Guy Ficco of IRS Criminal Investigation made the announcement.