That would follow accords with Germany and the U.K. signed this month that will impose new levies beginning in 2013 on Germans and Britons with Swiss offshore bank accounts.
Baer agreed with German authorities in April to a one-time payment of 50 million euros ($68 million) to end investigations against the bank and its employees over undeclared client assets. That was "cheap to settle" compared with the possible outcomes of "harsher" U.S. investigations, Becker said.
Baer's Casadei worked at the bank from the early 1990s through last year, and Frazzetto worked there from 2005 until last year, according to the new indictment. Both men, who live in Switzerland, are charged with conspiracy and face as long as five years in prison.
'Red Rubin'
They opened undeclared accounts for taxpayers under fictional names such as "Hydrangea" and "Red Rubin," according to a statement by U.S. Attorney Preet Bharara.
Casadei, Frazzetto and others told U.S. clients that their accounts "would not be disclosed to the IRS because Swiss Bank No. 1 had a long tradition of bank secrecy and no longer had offices in the United States, making Swiss Bank No. 1 less vulnerable to pressure from U.S. law enforcement authorities than other Swiss banks with a presence in the U.S.," Bharara said.
Tax attorney Lawrence Horn said the Justice Department is increasing its pressure on Julius Baer. Horn, of Sills Cummis & Gross PC in Newark, New Jersey, said he expects the U.S. government to hold the bank liable for the actions referred to in the indictment.
Julius Baer and other banks, he said, "are being boxed in right now. They really have nowhere to go."
The case is U.S. v. Casadei, 11-cr-866, U.S. District Court, Southern District of New York (Manhattan).