In 2008, an American employee of the bank, working in Switzerland, revealed that UBS had thousands of US customers who had opened accounts to avoid paying US taxes. The bank signed a consent agreement in 2009, agreeing to pay a $780 million fine and give the names of 250 account holders. But the IRS was pressing for a broader disclosure—the names of US citizens who held 52,000 numbered accounts worth an estimated $18 billion.
