Many offshore investors have failed to comply with requirements  that they alert the U.S. government to their offshore funds, including requirements to file an annual Report of Foreign Bank and Financial Accounts. The U.S. government has been aggressively cracking down on these investors in recent years, including entering into deals with foreign banks whereby those foreign financial institutions turn over information on accountholders in exchange for avoiding prosecution for facilitating tax evasion.

Many foreign financial institutions have made the decision to cooperate with the government of the United States in the government's tax-evasion investigations. Foreign banks have participated in a Swiss Bank Program, which allows them to come forward to disclose the ways in which they facilitated tax evasion. When these banks pay a fine and offer the U.S. government information on accountholders, the banks can avoid criminal prosecution. Financial institutions have also entered into similar deals with the U.S. outside of this formal amnesty program, protecting themselves from harsh penalties by turning over the information the IRS and Department of Justice need to investigate individual taxpayers.