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BANKING

                                  money with one of the strictest secre-    which in recent years Switzerland was
                                  cy laws in the world, decades later.      in a way gradually preparing for what
                                                                            should happen in 2018. In accordance
                                      But what has changed and what has     with the so-called „Program for Non-
                                  led Swiss banks to disclose the identity  Prosecution Agreements“ or so-called
                                  of their depositors? The global finan-    „Non-Target Letters for Swiss Banks“,
                                  cial crisis, which later extended into    published by the US Ministry of Justice
                                  a debt crisis, prompted USA and the       on August 29, 2013, the Swiss banks
                                  European Union to seek new sources        were asked to classify themselves in
                                  of tax revenue. In this quest, the un-    one of the three categories of non-
                                  taxed funds that the citizens of these    compliance with US tax regulations
                                  countries have managed to transfer to     and to start cooperation with the US
                                  countries that refuse to disclose the     tax authorities in sharing information
                                  identity of their depositors were high    on unregistered funds of American
                                  on the list. Of course, Switzerland       taxpayers. Consequently, given the
                                  was on top of the list of these coun-     costs associated with the procedures
                                  tries. The pressure on Switzerland as     and the certain costs for penalties
                                  a country and on the Swiss banks is       and agreements with US regulators
                                  evident from a number of processes        the Swiss regulator FINMA, in its No-
                                  that US authorities raised against        tice no. 56 from January 2014, urged
                                  global Swiss banks in which (or with      the banks to assess these costs and
                                  whose assistance) many US compa-          respectively allocate adequate provi-
                                  nies and individuals managed to avoid     sions for the financial year ended De-
                                  paying taxes in the United States. No     cember 31, 2013. After the penalties
                                  lesser was the pressure from Germa-       paid by the large Swiss banks such as
                                  ny, Great Britain and several other       UBS AG and Credit Suisse AG, which
                                  European countries. This has practi-      were accused of aiding tax evasion by
                                  cally initiated the process through       US companies and natural persons,
                                                                            the Swiss government agreed to adopt
Switzerland, the largest offshore financial center, will                    the standard for data exchange if it
completely abandon the principles of protecting the                         becomes global. This is in view of the
identity of non-resident depositors in 2018 and start                       fact that the global application cre-
the automatic exchange of information with the tax                          ates equal operating conditions for
authorities of a number of countries-signatories of the                     all financial centers in the world and
OECD Agreement                                                              reduces the external vulnerability of
                                                                            Switzerland.

                                                                               Switzerland has already signed bi-
                                                                            lateral agreements with a number
                                                                            of countries on the basis of which it
                                                                            shares information on the deposits
                                                                            of citizens of these countries upon
                                                                            request of their tax authorities. This
                                                                            gradually started to melt the so-called
                                                                            value added of Swiss banks and global
                                                                            banks with their branches in Switzer-
                                                                            land dealing with private banking. No
                                                                            one currently knows how much of the
                                                                            funds deposited in these banks are
                                                                            due to the motive of tax evasion. Esti-
                                                                            mates are that this percentage ranges
                                                                            between 30 and 60 percent. According
                                                                            to Boston Consulting Group, despite
                                                                            the initiated process of outflow of

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