Law360, New York ( February 16, 2016, 5:58 PM EST) -- The U.S. Department of Justice's Tax Division recently marked an historic milestone in its ground-breaking Swiss Bank Program with its recent announcement of the final nonprosecution agreement for so-called "category 2" banks participating in the program. The Tax Division announced its 80th, and final, nonprosecution agreement on Jan. 27, 2016, a major achievement as the U.S. government continues its unrelenting crackdown on offshore tax evaders and their facilitators, including foreign banks and their employees and agents. All told, the 80 category 2 Swiss banks that resolved their criminal tax exposure with the U.S. government will pay more than $1.36 billion in penalties. Perhaps even more importantly, every category 2 bank in the Swiss Bank Program is required to cooperate in any future related criminal or civil proceedings, thereby ensuring that the Justice Department will have the complete assistance from each bank as the U.S. government pursues leads, and "follows the money," throughout the world....