The OVDP is designed to go after tax noncompliance globally and has raised billions in revenue. It uses a list of Foreign Financial Institutions & Facilitators to dictate whether the penalty is 27.5% or 50%. Mossack Fonseca’s actions in facilitating tax noncompliance go beyond simple ignorance and into actually aiding the tax noncompliance. They should join UBS, Sarasin, and the other banks for which they facilitated tax evasion on the IRS list of bad banks and facilitators.



