Credit Suisse Services AG Admits to Conspiring with U.S. Taxpayers to Hide Assets and Income in Offshore Accounts and Admits that Credit Suisse Breached Its Prior Plea Agreement

Credit Suisse Services AG pleaded guilty and was sentenced today to conspiring to hide more than $4 billion from the IRS in at least 475 offshore accounts. The guilty plea by the Swiss corporation is the result of a years-long investigation by U.S. law enforcement to uncover financial fraud and abuse.

In addition to the plea, 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 and 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 Plea Agreement, NPA, and documents filed in court today: from Jan. 1, 2010, and continuing until about July 2021, Credit Suisse AG, which had ultra-high-net-worth and high-net-worth individual clients around the globe, 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, and providing a variety of offshore private banking services that assisted U.S. taxpayers in the concealment of their assets and income from the IRS and allowed for their continued failure to file FBARs. Among other fraudulent acts, 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 and breached its May 2014 plea agreement with the United States.

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. 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.

Under today’s resolutions, Credit Suisse Services AG and, by extension, UBS AG, is required to cooperate fully with ongoing investigations and affirmatively disclose any information it may later uncover regarding U.S.-related accounts. The agreements provide no protections for any individuals. 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.

Acting Deputy Assistant Attorney General Karen E. Kelly of the Justice Department’s Tax Division, U.S. Attorney Erik S. Siebert for the Eastern District of Virginia, and Chief Guy Ficco of IRS Criminal Investigation (IRS-CI) made the announcement.

Special Agents from IRS-CI’s International Tax & Financial Crimes specialty group, a team based out of Washington, D.C. that is dedicated to uncovering international tax crimes, is investigating the case. The Justice Department’s Office of International Affairs provided critical assistance in obtaining important evidence.

Senior Litigation Counsels Nanette L. Davis and Mark F. Daly as well as Trial Attorney Marissa R. Brodney of the Tax Division, and Assistant U.S. Attorney Kimberly M. Shartar for the Eastern District of Virginia are prosecuting the case.