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“In a victory for the government, Pauley said individuals can’t assert a constitutional right against self-incrimination and refuse to disclose bank records to a U.S grand jury.  The records sought include the name in which each account is maintained, number of others tied to the account, the address of the bank, and the maximum value of each such account.  More than 38,000 Americans avoided prosecution by entering an IRS amnesty program in which they paid back taxes and penalties while disclosing the banks and bankers who helped them hide offshore accounts.”

http://www.bloomberg.com/news/2013-02-20/grand-jury-investigating-foreign-bank-accounts-u-s-judge-says.html