By committing to a single count of conspiracy under a plea agreement with the DOJ, BHS agreed to pay a total of more than $402 million, or about $139 million in reimbursement due to the IRS; the loss of approximately $124 million, which is the gross expense paid to BHS by U.S. taxpayers with unreported accounts with BHS; and a fine of approximately $139 million. The amount of the fine corresponds to a 25% discount for the cooperation of BHS.  The DOJ has previously consulted bank Leumi Group (see U.S. Dep`t. Dep`t of Justice, Press Release, Bank Leumi Admits to Assisting U.S. Taxpayers in Hiding Assets in Offshore Bank Accounts (December 22, 2014), available here: www.justice.gov/opa/pr/bank-leumi-admits-assisting-us-taxpayers-hiding-assets-offshore-bank-accounts) and Mizrahi-Tefahot Bank Ltd. (see U.S. Dep`t of Justice, Mizrahi-Tefahot Bank Ltd – Deferred Prosecution Agreement (Mar. 12, 2019), available here: www.justice.gov/opa/press-release/file/1176116/download). BHBM is Israel`s largest bank and operates primarily as a retail bank with about 250 branches throughout Israel and more than 2.5 million accounts.
In addition to retail banking, BHBM, through its retail subsidiaries and Global Private Banking Center, offered private banking services to its offshore and online clients. BHBM also owned Poalim Trust Services Ltd., which provides trust and management services. Outside of Israel, BHBM owned BHS, a Swiss subsidiary that set up private banks. BHS is headquartered in Zurich and had temporary branches in Geneva, Luxembourg and Singapore during the lawsuits. BHBM also had branches in New York, Miami, the Cayman Islands, the United Kingdom and Jersey. Assistant Principal Attorney General Richard E. “The Department of Justice continues to aggressively prosecute banks and other financial institutions that help U.S. taxpayers hide their income and assets in offshore bank accounts,” Zuckerman said.
Today, Hapoalim Bank is held accountable for its behavior – it has acknowledged its crimes, it will pay all the fees it earned, reimburse the lost tax revenues in the United States and pay a considerable fine. On the same day, the bank also agreed to pay additional fines of more than $US 30 million related to the conclusion of a three-year non-prosecution agreement (“NPA”) with the Money Laundering and Asset Collection Division of the DOJ and the United States. The U.S. Attorney for the Eastern District of New York to resolve an investigation into the bank`s involvement in a plot to launder bribes and bribes to senior football officials.  The DFS found that the bank, including temporarily through its New York subsidiaries, was engaged in illegal cross-border banking that knowingly facilitated the United States. . . .