Carl Levin actually said...

It is absurd that any country wants to make money off our loss of tax revenues, particularly friends.

And, again, these structures were being set up for the purpose of hiding who the true owner or beneficiary of the accounts were.

You agreed in court that, acting through your bankers and managers, you 'participated in a scheme to defraud the United States of America.'

Generally it needs to have a specific taxpayer.