In 2009, Lack told the customer not to join an IRS voluntary disclosure program that let U.S. taxpayers avoid prosecution by declaring their offshore accounts, according to the indictment. Lack offered also offered to provide fake documents to make the money appear to be the proceeds of a loan, according to the indictment.

'Practically Zero Percent'

Gadola met the customer on Nov. 6 in a Miami hotel and told him not to declare the account because the likelihood of detection was "practically zero percent," according to the indictment. Authorities, who secretly recorded the meeting, charged Gadola the next day. His case was made public Dec. 15.

Lack also provided a total of $180,000 in cash to a Texas customer in three meetings from 2003 to 2007, according to the indictment.

In avoiding prosecution, UBS agreed in February 2009 to give the IRS data on 250 accounts and later handed over data on an additional 4,450 accounts to resolve an IRS lawsuit. That spurred the voluntary disclosure program, which drew 15,000 taxpayers in 2009 and another 4,000 after that.

Offshore Accounts

Taxpayers who joined the program had to identify their offshore accounts, bankers and advisers, as well as how they moved their money. More than 200 of those taxpayers have been questioned as U.S. prosecutors build new criminal cases.

Since 2009, more than two dozen UBS clients have been charged, as well as several bankers and advisers. Prosecutors also have indicted seven European bankers of Credit Suisse Group AG on charges of conspiring to help clients in the U.S. evade taxes.

The bank said July 15 that the Justice Department notified it that it was a target of a criminal probe over former cross- border private-banking services to U.S. customers.

The Lack case is U.S. v. Lack, 11-cr-60184, U.S. District Court, Southern District of Florida (Fort Lauderdale). The Gadola case is U.S. v. Gadola, 10-cr-20878, U.S. District Court, Southern District of Florida (Miami).

 

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