Former Credit Suisse AG customers are being investigated by federal grand jurors in Miami trying to determine whether they engaged in tax fraud, expanding a long-running U.S. probe of the bank.
The customers include a Brazilian businessman whose residence on Fisher Island, Florida, was raided by Internal Revenue Service agents in 2021 and a Colombian family featured in a US Senate report last year about the bank's role in US tax evasion schemes, according to people familiar with the matter.
U.S. tax prosecutors are pursuing the cases as the Justice Department investigates whether Credit Suisse, now owned by UBS Group AG, helped Americans hide assets from the IRS despite pledging to end the practice a decade ago, said the people.
Credit Suisse pleaded guilty in 2014, paid $2.6 billion, and admitted it helped thousands of Americans evade taxes.
Last year, a Senate Finance Committee report said the bank continued to help Americans avoid federal taxes. It detailed "major violations" of its plea deal, including helping the family hide $100 million from the IRS. Prosecutors are trying to determine if Credit Suisse breached its plea deal. Such a declaration could ultimately cost UBS $1 billion or more in penalties, the people said.
UBS is trying to resolve a liability it assumed when it acquired Credit Suisse last year for 3 billion francs ($3.26 billion) in a deal brokered by the Swiss government after years of scandal and mismanagement at Credit Suisse.
Lawyers for UBS have worked for the past year to persuade the Justice Department to resolve the matter civilly rather than declaring it in breach of its plea deal, said the people, who declined to be identified because the proceedings are confidential.
A UBS spokesperson declined to comment on the grand jury investigations. In a regulatory filing last month, it said: "Credit Suisse AG has provided information to US authorities regarding potentially undeclared US assets held by clients at Credit Suisse AG since the May 2014 plea. Credit Suisse AG continues to cooperate with the authorities."
The current investigations have focused on how taxpayers may have turned to family members or close friends with non-US passports to hide overseas accounts from the IRS, the people said. Prosecutors are looking at whether the bank assisted the practice or should have detected it.
Under the plea deal, Credit Suisse must identify undeclared accounts to the IRS. Since 2014, the bank had identified "thousands of previously undeclared accounts" valued at more than $1.3 billion, according to the Senate committee.
That included about two dozen with accounts of $20 million or more, and one involved a U.S. taxpayer, Dan Horsky, who pleaded guilty in 2016 to concealing $220 million in assets.
Deputy Attorney General Lisa Monaco has pledged to crack down on companies that repeatedly engage in criminal behavior.
