On 19th July, a release on Mondo Visione from the US DoJ announced that it had signed an addendum to a non-prosecution agreement with Banque Bonhôte & Cie SA, Ltd under the Swiss Bank Program.  The original non-prosecution agreement was signed in 2015.   At that time, Bonhôte reported that it held and managed 63 US-related accounts, with assets under management exceeding $88 million, and paid a penalty of $624,000.  Under the new agreement, Bonhôte acknowledges it should have disclosed additional US-related accounts to the DoJ at the time of the signing of the original non-prosecution agreement.  The Swiss Bank Program of 2013 provided a path for Swiss banks to resolve potential criminal liabilities in the US relating to offshore banking services provided to US taxpayers.

This blog is primarily for my own use, to keep informed and up to date. However, if you would like to say thank you (and perhaps help me get a new, better laptop when I am away…) you can “buy me a coffee” at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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