If the bank spits out more names, it will reduce its risk of a ruinous U.S. criminal prosecution or of being kicked out of an IRS program--known as the qualified intermediary program--that is essential to its ability to do business internationally.

FORBES: End of an Era?

Among the accusations: The bank encouraged its American customers to open accounts in the name of Lichtenstein foundations to conceal their ownership, and it advised them how to set up their investments to fly under the radar of the Qualified Intermediary program.

FORBES: Tax Havens Under Attack By Congress