The DOJ and IRS did not immediately comment. HSBC declined to comment.

The message for anyone with an offshore account who hasn't yet stepped forward? It is the same as it was in the UBS case: Waste no time in contacting the IRS. Those who do can "basically assure they'll have a civil resolution," said Rettig.

Those who don't could get a letter from the IRS or the DOJ, and that letter may mean the start of a criminal case.

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