By Lynnley Browning  
    (Reuters) - The United States indicted Wegelin, the oldest    Swiss private bank, on charges that it enabled wealthy    Americans to evade taxes on at least $1.2 billion hidden in    offshore bank accounts, the U.S. Justice Department said on    Thursday.  
    The announcement, by federal prosecutors in Manhattan,    represents the first time an overseas bank has been indicted by    the United States for enabling tax fraud by U.S. taxpayers.  
    The indictment said the U.S. government had seized more than    $16 million from Wegelin's correspondent bank, the Swiss giant    UBS AG, in Stamford, Connecticut, via a separate civil    forfeiture complaint. Because Wegelin has no branches outside    Switzerland, it used correspondent banking services, a standard    industry practice, to handle money for U.S.-based clients.  
    UBS could not be reached for immediate comment.  
    The charges against Wegelin, of fraud and conspiracy, provide a    rare glimpse into the world of Swiss private banking in the    wake of a crackdown on UBS AG. In 2009, UBS paid $780 million    and entered into a deferred prosecution agreement with the    Justice Department over charges it engaged in fraud and    conspiracy by enabling scores of Americans to evade taxes    through its private bank. The bank later turned over the names    of more than 4,500 clients, a watershed in Swiss bank secrecy,    which protects the confidentiality of clients and their data.  
    The indictment signals a ramping up of pressure on 10 other    Swiss banks under investigation by the Justice Department,    including Credit Suisse, Julius Baer and Basler Kantonalbank.  
    Six days ago, Wegelin -- founded in 1741 -- effectively broke    itself up by selling the non-U.S. portion of its business. The    indictment represents the latest blow to the tradition of Swiss    bank secrecy in a long-running U.S. crackdown on tax dodgers.  
    Switzerland is seeking a global solution for its entire banking    industry, not just the 11 banks under criminal scrutiny.  
    On Tuesday, the Swiss finance ministry handed U.S. authorities    encrypted data on bank employees who served U.S. clients    suspected of dodging taxes, and said it would only provide the    key to decipher the data once the row was settled.  
    ACCOUNTS FOR FORMER UBS CLIENTS?  
    The U.S. Justice Department said Wegelin "affirmatively decided    to capture for Wegelin the illegal U.S. cross-border banking    business lost by UBS and deliberately set out to open new    undeclared accounts for US taxpayer-clients leaving UBS," the    indictment said. U.S. clients were told that Wegelin presented    less risk amid the crackdown because it had no branches outside    Switzerland and "had a long tradition of bank secrecy."  
    The indictment also accused Wegelin of helping two unnamed    Swiss banks "repatriate undeclared funds to their own U.S.    taxpayer-clients by issuing checks drawn on Wegelin's Stamford    correspondent account." The transfers were separated into    chunks below the $10,000 threshold at which such transfers are    reported to the IRS. Wegelin, the indictment said, "co-mingled"    the repatriated funds with other, unrelated funds, to better    conceal their origin and nature.  
    The charges against Wegelin were filed as a superseding    indictment of three previously charged Wegelin bankers: Michael    Berlinka, Urs Frei and Roger Keller. The three men were charged    on January 4 with fraud and conspiracy. The superseding    indictment named several unindicted co-conspirators, including    one who served as a team leader for the three men at the Zurich    branch.  
    The charges provided new details on how the bank worked to    solicit new U.S. clients fleeing UBS. According to the    indictment:  
    * Wegelin, one of the last "pure" private banks, is principally    owned by eight managing partners and run by an executive    committee that included partners. One unindicted    co-conspirator, named as Executive A at the bank, was a member    of Wegelin's executive committee and worked in Zurich.  
    * Wegelin used a special code, "BNQ," on around 70 new U.S.    undeclared accounts that were opened over 2008 and 2009. It    also sometimes opened accounts for U.S. citizens who held    passports from other countries, and opened the accounts through    the non-U.S. passports.  
    * Wegelin recruited U.S. clients through a website,    http://www.SwissPrivateBank.com, that was run by an unidentified third    party. The website boasted there that "Swiss bank secrecy is    not lifted for tax evasion ... Neither the Swiss government nor    any other government can obtain information about your bank    account." Unlike the United States, Switzerland generally does    not consider tax evasion to be a crime.  
    * Wegelin gave accounts special names, including "Elvis" and    "Limpopo Foundation." The charges detailed the bank's work for    nearly three dozen American clients, known only as clients A    through JJ.  
    * Wegelin encouraged clients not to come forward to the U.S.    Internal Revenue Service and disclose their names in exchange    for reduced penalties. Clients who did so in recent years    helped provide the Justice Department with a roadmap to the    inner workings of Wegelin - a map that led to the bank's    indictment.  
    (Reporting By Lynnley Browning in Hamden, Connecticut; Editing    by Kevin Drawbaugh, Howard Goller, Phil Berlowitz)  
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U.S. Justice Department indicts Swiss bank Wegelin