The bankers, Michael Berlinka, Urs Frei and Roger Keller allegedly "opened and serviced dozens of undeclared accounts," in 2008 and 2009, picking up business from UBS and another unidentified bank, which had stopped servicing undeclared accounts for U.S. taxpayers after settling a tax-evasion case with the Justice Department in 2009.
UBS paid $780 million in fines handed over account information to the IRS to settle its case.
The indictment issued this week does not reveal the bank where the three defendants work. It is identified only as "Swiss Bank A."
The indictment alleges the three bankers told U.S. clients that Swiss banks had a "long tradition of bank secrecy," as a means of capitalizing on UBS closing its undeclared accounts.
The bankers then "opened and serviced undeclared accounts for U.S. taxpayer-clients in the names of sham corporations and foundations formed under the laws of Liechtenstein, Panama, Hong Kong and other jurisdictions for the purpose of concealing identities," the indictment says.
The defendants face a maximum sentence of five years in prison and fines of up to $250,000 if convicted.
The case was assigned to U.S. District Judge Jed Rakoff, who has made headlines in recent years for refusing to sign off on a $33 million Bank of America settlement in a case brought by the Securities and Exchange Commission concerning the bank's alleged misstatements to shareholders during its 2009 purchase of Merrill Lynch.