It is difficult for me to accept that, when you do not try to enforce a subpoena, when you do not go to a court when you have a subpoena which you have issued, to enforce it to get records, to help put the pressure on a bank.

And wouldn't we make a pretty clear point about our determination also about the Swiss being unhelpful if we file a request for extradition, in a criminal case, for people who have operated in the United States.

They should be subject to U.S. transparency and not shielded by Swiss secrecy.

The trouble is that the Justice Department has been deterred by the Swiss Government's law.

Client 1 opened the account in 2005, not in 1990.

Now the Swiss banks sought out U.S. clients. They traveled here. They sold Swiss secrecy to U.S. taxpayers.

Thank you so much, Senator McCain.

Of course, but it means you have substantial evidence.

Was the major mission--not significant portion, major mission--of those detailed attorneys tax enforcement?

The billions of dollars that are uncollected in taxes, and there are a lot of reasons for that, but you folks have to look in the mirror if you want to help us identify one reason and go after the folks who have evaded paying taxes.

Is he one of the people you are going to be speaking to as part of that investigation?

So do not tell us the treaty is going to get us what we want. It will not.

the U.S. interest in criminal prosecutions outweighs the foreign jurisdiction's interest in secrecy.

UBS' actions sent a powerful signal that U.S. tax cheats using offshore accounts better pay up or face prosecution.

OK. Well, that is what happened here.

In the first quarter, the NNA, net new asset, for Client 5 was actually split 60/40 between Americas and Switzerland.

Now, the bank told us about 150 trips by 10 Swiss bankers to the United States from 2002 to 2008.

Well, would you give us a list of the reports that we have asked for that you have not shared them with this Subcommittee and the reason that you have not shared?

Thank you very much, Senator Johnson.

But did you tell them that you had never made such an agreement?

What it tells me is the best way to go about it is to build a strong criminal case against the banks in Switzerland who are fostering the tax evasion by U.S. citizens.

But in any event, you acknowledge that misconduct was not all in this one area of the bank.

You are not constrained about talking about whether or not, as a policy, you go to the Fed if there is a violation of a court order and urge the Fed to withdraw a license.

OK. And the second quarter, the NNA for Client 5 was not split at all. It was entirely credited to Americas.

You don't want to be in the dirty business any longer of helping U.S. clients cheat on their taxes.