The Foreign Account Tax Compliance Act (FATCA) requires all U.S. citizens to file annual reports of their financial accounts held outside of the United States.  This is true even of people who live outside of the U.S. and have accounts in the country they currently consider home.  The goal of FATCA is to make sure that U.S. accountholders are reporting all income and complying with all U.S. tax obligations. 

The United States Department of Justice has created the Swiss Bank Program to make it possible for banks to avoid criminal consequences for helping U.S. accountholders evade their reporting and income tax obligations. The Swiss Bank Program creates different categories of banks.

The Department of Justice has created the Swiss Bank Program, which is essentially an amnesty program allowing banks to come forward and negotiate deals to avoid serious criminal penalties for helping to facilitate tax evasion. Banks pay fines to U.S. authorities and agree to provide details about their cross-border activities, as well as information about specific accounts in which U.S. taxpayers have a direct or an indirect interest.