In recent years, the Justice Department charged dozens of corporations with crimes and agreed to defer prosecution in exchange for companies paying fines, making required reforms and admitting wrongdoing. Prosecutors typically agree to drop the charges after one or two years if companies meet those terms.

Aside from the UBS deferred-prosecution agreement, Credit Suisse agreed in December 2009 to pay $536 million to resolve claims that it helped process payments to let Iran and other nations avoid government sanctions and gain access to U.S. financial markets.

Since 2009, about 30,000 U.S. taxpayers have avoided prosecution by disclosing their undeclared accounts to the IRS through a limited amnesty program, Douglas Shulman, the commissioner for the agency, said Sept. 15. Shulman said that 12,000 taxpayers had voluntarily disclosed their accounts in a second round of the program offered this year. He said the IRS had taken in $2.7 billion from holders of offshore bank accounts.

"You'd have to be living in a hole not to know that the U.S. government is really focused on offshore tax evasion," Shulman said in a conference call.

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