There once was a time when wealthy Americans with money stockpiled abroad in Swiss banks could sleep easily at night, knowing that their account details would be kept shielded from the prying eyes of United States Internal Revenue Service agents.

That time has assuredly passed.

The new reality is this: Americans holding overseas savings accounts and not duly reporting relevant information regarding them to the IRS are being systematically hunted by the tax agency, which is using powerful enforcement tools to coerce compliance.

As noted in media accounts last week, the arm twisting extends beyond the mere laser-type focus the IRS is now placing upon individual investors. Foreign banks, too, are targets of IRS investigations.

The bank BSI SA can certainly attest to that. The institution — a top-10 bank in Switzerland — became last week the first private financial institution to ink a so-called non-prosecution agreement with the U.S. Treasury Department. In lieu of facing severe criminal penalties for its alleged involvement in promoting tax evasion by secretly helping well-heeled American investors evade lawful tax payments, the bank agreed to pay a $211 million penalty.

And, coupled with that exaction, a host of other duties were also imposed upon BSI SA. The bank agreed to provide the IRS with “detailed information on an account-by-account basis” for every account opened by an American taxpayer, regardless of its size or status. It also disclosed details on how its cross-border business involving American account holders worked and gave the IRS information on all its American account holders dating back several years.

A ranking federal attorney stated that, while BSI SA was the first bank to execute a non-prosecution agreement with the IRS, “it will not be the last.”

Source: USA TODAY, “Swiss bank pays $211M for aiding tax evasion,” Kevin McCoy, March 30, 2015