In the recent days much has been written about the draft of the Non-Prosecution Agreement (NPA) that the Category 2 banks have received. The NPA is aimed at the banks that are not already under investigation by the US Department of Justice (DoJ) but have reasons to believe that they have committed tax-related offenses in regards of US-linked assets. The major point is the request for ‘total cooperation’. It is still very unclear what this ‘total cooperation’ entails. This seems to not only adjust the past for dirty money but link the banks to the US for information in the future as well.

The forced cooperation here is not limited to the DoJ but to the full state bodies in the USA, including the IRS.  

This was largely discussed in various media in the last few days

Inside Paradeplatz