Raiffeisen announced that they have sent a Letter of Intent to the US Department of Justice (DoJ) to show their intention of participating in the US Program under Category 3. Category 3 banks are those that believe they have not engaged in activities that could have breached US law. An Independent Examiner (e.g. US or Swiss law firm or accountant) needs to verify this. Information about the total managed US assets needs to be provided by these banks as well as a confirmation that effective compliance programs are in place. They do not need to pay a penalty but the handling costs endured by fulfilling the requirements of the US Program is born by these banks. They will be able to seek Non-Target Letters (NTL).
The report of the Independent Examiner will be ready by April 30, 2015.