The Justice Department just recently announced its latest catch: Peter Amrein, a Swiss citizen and former asset manager at a Swiss asset management firm. Mr. Amrein pleaded guilty to one count of conspiracy to defraud the IRS, to evade federal income taxes, and to file false federal income tax returns. By way of his allocution during the plea hearing, Mr. Amrein acknowledged entering into an agreement with U.S. taxpayer-clients and others to help U.S. taxpayers hide millions of dollars in offshore accounts from the Internal Revenue Service (IRS), and to evade U.S. taxes on the income earned in those accounts.

The allegations in the superseding Information and the prior indictment lay out the sordid details. Mr. Amrein started out as a client advisor at a Swiss bank (Swiss Bank No. 3), later working his way up to an asset manager at a Swiss asset management firm (the Swiss Asset Management Firm). In those roles, Mr. Amrein helped U.S. taxpayers hide millions of dollars in unreported accounts at numerous Swiss banks over a twelve-year period.

One of those banks was Wegelin & Co. If that name sounds familiar, that’s because it became the target of a U.S. government probe that resulted in criminal charges. It captured major headlines after pleading guilty for conspiring with U.S. taxpayers to evade taxes. Working with a Zurich-based attorney, Mr. Amrein established sham foundations, which were organized under the laws of non-U.S. countries such as Liechtenstein. The purpose of establishing these foreign foundations was to disguise the identity of the true owners of the unreported account: Mr. Amrein’s U.S. taxpayer-clients. This made it difficult for the IRS to determine who the true owners of these unreported accounts were.

Back in 2008, UBS AG (UBS) was the talk of the town. A day didn’t go by that a major newspaper didn’t run a story on how UBS was being investigated by U.S. law enforcement for helping U.S. taxpayers hide offshore accounts in Switzerland. Due to the publicity surrounding the UBS investigation, one of the Swiss banks where Mr. Amrein had opened up unreported accounts for U.S. taxpayers (Swiss Bank No. 4) became skittish. They decided to close these unreported accounts.

In order to assist his clients in not reporting their accounts to the IRS, Mr. Amrein searched for other banks in Switzerland that were still willing to thumb their nose in the face of the U.S. government by opening unreported accounts for U.S. taxpayers, despite the public investigation of UBS. Mr. Amrein found just such a bank: Swiss Bank No. 1. Over the next several years, Mr. Amrein opened undeclared accounts for U.S. taxpayer-clients at Swiss Bank No. 1 in the name of sham foundations. Mr. Amrein funded these accounts by transferring his clients’ undeclared assets from Swiss Bank No. 4 to Swiss Bank No. 1.

Unfortunately, it only gets worse. Mr. Amrein, working with a network of other co-conspirators, helped repatriate funds back to the United States and to other foreign jurisdictions in ways that were designed to ensure that his clients’ unreported accounts would go undetected by the IRS. For example, Mr. Amrein instructed a client advisor at Swiss Bank No. 1 (the Swiss Bank No. 1 Client Advisor) to empty one of the accounts by sending checks in amounts smaller than $9,900 to the beneficial owner of the account (i.e., the U.S. taxpayer).

On another occasion, Mr. Amrein instructed the Swiss Bank No. 1 Client Advisor to transfer the balance of one of the accounts, which was then valued at more than $2.4 million, to another account controlled by the U.S. taxpayer in Belize City, Belize. As late as 2011, Mr. Amrein was actively seeking other Swiss banks that were still willing to open unreported accounts for U.S. taxpayers.  For example, in June 2011, Amrein met with a client advisor at a Swiss bank (Swiss Bank No. 2), to discuss opening unreported accounts for U.S. taxpayer-clients at Swiss Bank No. 2.