The aggressive push by the feds has put the bank in a crossfire between U.S. law and the laws of Switzerland, which treats disclosure of customer information as a crime.

''The era of bank secrecy in Switzerland is dwindling to a close,'' says Scott Michel, a tax attorney with Caplin & Drysdale in Washington, D.C., who has a couple of dozen UBS clients hoping to settle tax problems related to the secret offshore accounts.

The keen scrutiny also comes as UBS has been reeling from subprime mortgage losses. In October, the bank got a $60 billion bailout from the Swiss government.

The veil on UBS' private banking operations began to lift in May when federal prosecutors in Fort Lauderdale unsealed an indictment against former UBS banker Birkenfeld, a Bostonian who worked in Switzerland. Federal investigators say his primary duties were to find new clients in the United States.

Birkenfeld's top client was Igor M. Olenicoff, a billionaire California developer who has a home in Lighthouse Point. Olenicoff pleaded guilty last December to one count of filing a false tax return and paid $52 million in back taxes and penalties. He has since sued UBS, among others, for what he called poor financial advice that steered him into his legal woes and for allegedly mishandling his funds. UBS has denied the claims, made in a federal suit in Los Angeles.

UBS was formed in the 1998 merger of Union Bank of Switzerland and Swiss Banking Corp., two old-line Swiss institutions that had largely stuck close to home.

After the merger, the new bank pushed hard to expand globally, dramatically raising its U.S. profile with the acquisition of U.S. brokerage giant PaineWebber in 2000.

According to a Senate Permanent Subcommittee on Investigations report, UBS prodded its private bankers to bring in new money from U.S. clients. Between 2004 and 2006, UBS client advisors on average quadrupled the new money brought in from the Americas, according to one executive memo cited in the report. A company business plan noted that the United States ``has 222 billionaires with a combined net worth of $706 billion.''

Birkenfeld was one of about 60 private bankers who, with management's encouragement, went to the United States several times a year to cater to clients with secret offshore accounts, the government alleges.

HELPING THE FEDS

In June, Birkenfeld pleaded guilty and agreed to cooperate, acknowledging a litany of deceptions, including stealthily toting diamonds into the United States in a tube of toothpaste. He remains free on bond, and his sentencing has been delayed several times while he helps investigators.

The IRS, armed with details of UBS' cross-border operations provided by Birkenfeld, got a federal judge in Fort Lauderdale to approve the civil summons ordering UBS to turn over names of clients with undeclared overseas accounts. Under U.S. law, taxpayers are required to disclose foreign bank accounts with at least $10,000; income from those accounts is subject to U.S. taxes.

At least one UBS client has gone to court in Switzerland to block disclosure of bank records. UBS, separately, has turned over the names of about 70 customers who wired money from the United States to Switzerland, but that entailed U.S.-based bank records, not Swiss.

In addition to the Justice Department and IRS investigations, the Securities and Exchange Commission had launched a probe into whether the bank violated federal securities law by dealing with U.S. clients through unregulated and unlicensed offshore units. The district attorney's office in Manhattan had launched a parallel tax probe of its own.

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