An email from Christine Mazzella (IRS) to James C. Lee, cc Justin Cole, dated April 6, 2022, summarizing the rationale and context for OCIF's de-banking of Euro Pacific Bank (EPB). The document outlines OCIF's examination findings—including bank failures to comply with consent orders, failure to provide financial statements (with Deloitte de-qualifying 2019 statements), misrepresentation to OCIF, negative capitalization, and insufficient ownership competence. It notes EPB had very few employees in Puerto Rico. The second page argues that while criminal/civil impact on U.S. taxpayers may be minimal, the IRS-OCIF collaboration demonstrates proactive oversight of a high-risk jurisdiction, increases voluntary compliance with Puerto Rico laws, and will help the U.S. Department of Treasury counter future attempts to label Puerto Rico as a high-risk/tax haven jurisdiction.
