On Aug. 29, 2013, the Department of Justice announced the Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks.1 Between March 30, 2015, and Jan. 27, 2016, the DOJ entered into 78 non-prosecution agreements with a total of 80 Swiss banks, collecting more than $1.3 billion in penalties, getting a trove of information regarding accounts related to U.S. taxpayers, and ensuring the cooperation of participating banks.
Caroline Ciraolo has served as the Acting Assistant Attorney General of the DOJ’s Tax Division since Feb. 25, 2015. In that capacity, she leads the department’s civil and criminal tax enforcement efforts. In an interview with Law Journal columnist Jeremy Temkin, Ciraolo discussed the status of the Swiss Bank Program, the Tax Division’s commitment to offshore enforcement and its challenges going forward. Jeremy Temkin: How did the Swiss Bank Program work and what did the Tax Division accomplish though the program? Caroline Ciraolo: The Swiss Bank Program is an innovative approach to offshore enforcement and represents the best of what can be achieved through ingenuity and collaboration. It has been strongly supported by the department’s senior leadership, and has benefited greatly from the assistance of IRS-Criminal Investigation and the IRS Large Business and International Division.