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Press Release

Former Swiss Executive Pleads Guilty To Tax Fraud Conspiracy

For Immediate Release
U.S. Attorney's Office, Southern District of New York

Damian Williams, the United States Attorney for the Southern District of New York, and Stuart M. Goldberg, Acting Deputy Assistant Attorney General of the Justice Department’s Tax Division, announced that ROLF SCHNELLMANN, a Swiss former executive, pled guilty today to conspiring to defraud the United States in connection with a scheme to help high-value U.S. taxpayer-clients conceal more than $60 million in income and assets held in undeclared, offshore bank accounts and to evade U.S. income taxes.  SCHNELLMANN pled guilty before U.S. District Judge Gregory H. Woods. 

According to the allegations in the Indictment, court filings, and statements made in Court:

SCHNELLMANN was the former head of Allied Finance Trust AG, a Zurich-based financial services company that was a subsidiary of the Allied Finance Group in Liechtenstein.  From in or about 2008 to in or about 2014, SCHNELLMANN and his co-conspirators defrauded the IRS by concealing income and assets of high-value U.S. taxpayer-clients with undeclared bank accounts at Privatbank IHAG Zurich AG (“IHAG”), a Swiss private bank.  In order to assist the U.S. taxpayer-clients, SCHNELLMANN and his co-conspirators devised and implemented a scheme dubbed the “Singapore Solution” to fraudulently conceal the bank accounts of the U.S. taxpayer-clients, their assets, and their income from U.S. authorities.  In furtherance of the fraudulent scheme, SCHNELLMANN and his co-conspirators conspired to transfer more than $60 million from undeclared IHAG bank accounts of the U.S. taxpayer-clients through a series of nominee bank accounts in Hong Kong and other locations before returning the funds to newly opened accounts at IHAG in the name of a Singapore-based asset-management firm that a co-conspirator helped establish.  The U.S. taxpayer-clients paid large fees to IHAG and others to help them conceal their funds and assets and evade taxes. 

SCHNELLMANN was arrested in August 2023 in Italy and extradited to the United States.

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SCHNELLMANN, 61, of Switzerland, pled guilty to one count of conspiracy to defraud the United States, which carries a maximum sentence of five years in prison.  SCHNELLMANN is scheduled to be sentenced by Judge Woods on July 19, 2024, at 10:00 a.m.

The maximum potential sentence in this case is prescribed by Congress and is provided here for informational purposes only, as SCHNELLMANN’s sentence will be determined by the judge.

Mr. Williams praised the outstanding work of the Internal Revenue Service, Criminal Investigation.  Mr. Williams also thanked the Department of Justice’s Office of International Affairs, Interpol, Italian law enforcement authorities, the Prosecutor General’s Office of Trieste, and the Italian Ministry of Justice for their assistance in the extradition of the defendant.  Mr. Williams thanked the Department of Justice’s Tax Division for their partnership on this case. 

This prosecution is being handled by the Complex Frauds and Cybercrime Unit and the Department of Justice’s Tax Division.  Assistant U.S. Attorney Olga I. Zverovich and Senior Litigation Counsel Nanette Davis of the Tax Division are in charge of the prosecution.


Nicholas Biase
(212) 637-2600

Updated December 21, 2023

Press Release Number: 23-446