The U.S. Tax Program for Swiss banks: what determined the penalties?

The U.S. Tax Program for Swiss banks is a very significant part of the recent history of the Swiss financial industry. It has accelerated the transformation of the Swiss banking industry from a system that relied on bank secrecy to a much more compliant one. It was also rather costly for the banks involved. This short paper tries to identify the determinants of the individual penalties that were levied by the DoJ. We find that U.S. assets under management is the most important determinant. However, the average size of the accounts, the behavior of the bank vis-à-vis its American clients, the solvency of the bank, and the point in time when the bank settled with the DoJ also matter.