US Attorney Announces Sealing of Indictment Charging Six People and One Company with Tax Evasion Conspiracy and Related Guilty Pleas | USAO-SDNY
Audrey Strauss, United States Attorney for the Southern District of New York, Stuart M. Goldberg, Acting Assistant Attorney General of the Tax Division of the Department of Justice, and James C. Lee, Chief of the Internal Revenue Service, Criminal Investigation (“IRS -CI”), today announced that it has lifted the seal of an indictment accusing six foreigners and a Swiss financial services company of conspiring to defraud the IRS by helping three taxpayers – Valuable US clients to conceal more than $ 60 million in undeclared income and assets held, offshore bank accounts and to evade US income tax. The case was referred to the judge of US District Gregory H. Woods One of the accused was recently arrested in Spain.
Ms Strauss, Mr Goldberg and Mr Lee also today announced the unveiling of the guilty plea of Wayne Franklyn Chinn, one of the US taxpayer-clients who participated in the tax evasion scheme. The case against CHINN is attributed to US District Judge Victor Marrero. As part of a related civil confiscation action, the government confiscated approximately $ 2.2 million of untaxed funds from CHINN and repatriated those funds from Singapore to the United States.
Manhattan US attorney Audrey Strauss said: “As alleged, the individual defendants and Swiss company Allied Finance conspired to defraud the IRS by helping US taxpayers evade their tax obligations. They allegedly did so through an elaborate ploy of concealing the assets of clients of a Swiss private bank through nominative bank accounts in Hong Kong and elsewhere, with the funds going to the private bank on behalf of a bank. Singaporean company. One of those American clients, Wayne Chinn, has pleaded guilty to participating in the so-called “Singapore Solution”, has confiscated over $ 2 million in the United States, and is awaiting conviction for his convicted crime.
Acting Assistant Deputy Attorney General Stuart M. Goldberg said: “Prosecution of overseas tax evasion remains one of the highest priorities of the Taxation Division. Taxpayers who plan to hide money abroad – and foreign bankers, lawyers, and financial professionals who design and execute strategies to aid their escape – should know that the Taxation Division and the IRS have investigative resources and expertise to unravel even the most elaborate schemes.
IRS-CI chief James C. Lee said: “The defendants have allegedly helped their clients conceal more than $ 60 million in income and assets in an attempt to evade their US tax responsibilities. Through the hard work of IRS-CI and the cooperation of our law enforcement partners, we were able to uncover the massive fraud allegedly perpetrated by these individuals and hold them accountable for their actions. We are also proud to recognize the guilty plea of Mr. Wayne Chinn. His actions demonstrate complete disregard for US tax laws, but thanks to the commitment of our agents, we were able to unravel his scheme and bring him to justice.
According to the indictment allegations unveiled today:
From 2009 or around 2009 to or around 2014, Ivo Bechtiger, Bernhard Lampert, Peter Rüegg, Roderic Sage, Rolf Schnellmann, Daniel Wälchli and Allied Finance Trust AG of Zurich, Switzerland (“ALLIED FINANCE”), the defendants, defrauded the IRS by concealing the income and assets of certain US taxpayers with undeclared bank accounts located at Privatbank IHAG Zurich AG (“IHAG”), a Swiss private bank in Zurich, Switzerland, and elsewhere. In order to assist US taxpayer-clients, the defendants and others devised and implemented a scheme dubbed the “Singapore Solution” to fraudulently conceal US taxpayer-client bank accounts, assets and income from authorities. American. In pursuit of the fraudulent scheme, the defendants and others conspired to transfer more than $ 60 million from undeclared IHAG bank accounts of three US taxpayers through a series of nominative bank accounts in Hong Kong and other places before to return funds to newly opened accounts. at IHAG on behalf of a Singapore-based asset management company. American taxpayers have paid IHAG and others significant fees to help them conceal their funds and assets and evade taxes.
On or around August 16, 2021, the accused PETER RÜEGG, 61, from Switzerland, was arrested in Spain. As alleged in the indictment, RÜEGG was a member of IHAG’s management and relationship manager for one of the US taxpayer-clients who participated in the Singapore Solution program. RÜEGG reportedly helped the US taxpayer-client conceal around $ 50 million in undeclared assets from IHAG via the Singapore solution.
If found guilty, the defendants face a maximum sentence of five years in prison and ALLIED FINANCE faces financial penalties.
The charges contained in the indictment are only charges, and the accused are presumed innocent until proven guilty.
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The guilty plea of Wayne Franklyn Chinn, one of the U.S. taxpayers who participated in the Singapore Solution program, was also released today. According to statements made during CHINN’s plea proceedings and related court documents:
From at least 2001 to at least January 2019 or around that date, CHINN concealed approximately $ 5 million in undisclosed and untaxed income for the 2001 to 2018 tax years. During this period, CHINN held offshore accounts at IHAG in the name of nominees. Starting in 2010, CHINN and others transferred funds from these offshore accounts to IHAG through nominated accounts outside of Switzerland, including in Hong Kong, before returning them to newly opened accounts at IHAG held. on behalf of a Singapore-based trust company allegedly on behalf of two foundations created by a co-conspirator. They did so to continue to conceal CHINN’s income and assets from US authorities. CHINN then transferred the funds outside of Switzerland to undeclared accounts in Singapore. CHINN did not file any tax returns or disclose its offshore bank accounts during the years in question.
CHINN, 79, of Ho Chi Minh City, Vietnam, and San Francisco, Calif., Pleaded guilty on December 19, 2019 before U.S. judge Kevin Nathaniel Fox to one count of tax evasion for years 2001 to 2018, violating 26 USC § 7201, punishable by up to five years in prison. CHINN also agreed to civil forfeiture of 83% of funds held in five accounts at two Singapore banks, resulting in the confiscation and repatriation to the United States of approximately $ 2.2 million. The civil confiscation procedure is United States of America v. Certain funds deposited in various accounts, 20 Civ. 3397 (LJL).
CHINN is set to be sentenced by Judge Marrero on November 19, 2021.
The potential maximum sentences set out above are prescribed by Congress and are provided here for informational purposes only, as any convictions of defendants will be determined by the court.
Ms. Strauss and Mr. Goldberg praised the outstanding work of the IRS-CI. Ms Strauss thanked the Taxation Division of the Department of Justice for its partnership in this matter. Ms. Strauss, Mr. Goldberg and Mr. Lee also thanked the International Affairs Office of the Department of Justice, the Singapore Attorney General’s Office and the Singapore Police Department of Business Affairs for their assistance in this matter.
This prosecution is managed by the Complex Fraud and Cybercrime Unit of the United States Attorney’s Office for the Southern District of New York and the Taxation Division of the Department of Justice. Deputy U.S. Attorney Olga I. Zverovich of the U.S. Attorney’s Office for the Southern District of New York and Senior Litigation Counsel Nanette Davis and Trial Lawyer Sean Green of the Tax Division are in attendance. charge of prosecution.
 As the introductory sentence indicates, the entire text of the Indictment and the description of the Indictment set out here constitute allegations only, and each fact described should be treated as an allegation. .
 In November 2015, IHAG entered into a no-prosecution agreement with the Justice Department, paid a fine of around $ 7.4 million, and agreed to cooperate with US authorities.