Swiss executive pleads guilty to tax fraud conspiracy


Date: March 30, 2023


Damian Williams, the United States Attorney for the Southern District of New York, Stuart M. Goldberg, Acting Deputy Assistant Attorney General of the Justice Department's Tax Division, and James C. Lee, Chief of the Internal Revenue Service, Criminal Investigation ("IRS-CI"), announced that Daniel Wälchli pled guilty today to conspiring to defraud the United States in connection with a scheme to help wealthy American clients conceal more than $60 million in income and assets held in undeclared offshore bank accounts and evade U.S. income taxes. Wälchli was a member of the executive board of a Swiss holding company that owned, among other entities, a Zurich-based private bank called Privatbank IHAG Zurich AG ("IHAG"). Wälchli pled guilty earlier today before U.S. District Judge Gregory H. Woods.

According to the allegations in the Indictment, court filings, and statements made in Court:

From in or about 2009 to in or about 2014, Wälchli and his co-conspirators defrauded the IRS by concealing income and assets of three wealthy U.S. clients with undeclared bank accounts at IHAG. In order to assist the U.S. clients, Wälchli and his co-conspirators devised and implemented a scheme dubbed the "Singapore Solution" to fraudulently conceal the bank accounts of the U.S. clients, their assets, and their income from U.S. authorities. In furtherance of the fraudulent scheme, Wälchli and his co-conspirators agreed to transfer more than $60 million from undeclared IHAG bank accounts of the U.S. clients through a series of nominee bank accounts in Hong Kong and other locations before returning the funds to newly opened accounts at IHAG in the name of a Singapore-based asset-management firm that Wälchli helped establish. The U.S. clients paid large fees to IHAG and others to help them conceal their assets and evade U.S. income taxes.

Wälchli of Switzerland, pled guilty to one count of conspiracy to defraud the United States, which carries a maximum sentence of five years in prison.

The maximum potential sentence in this case is prescribed by Congress and is provided here for informational purposes only, as Wälchli's sentence will be determined by the judge.

Mr. Williams praised the outstanding work of IRS-CI. Mr. Williams thanked the Department of Justice's Tax Division for their partnership on this case.

This prosecution is being handled by the Complex Frauds and Cybercrime Unit of the United States Attorney's Office for the Southern District of New York and the Department of Justice's Tax Division. Assistant U.S. Attorney Olga I. Zverovich of the United States Attorney's Office for the Southern District of New York and Senior Litigation Counsel Nanette Davis and Trial Attorney Christopher Magnani of the Tax Division are in charge of the prosecution.