Where the money went: accounts, numbers and bearer paper

The deposit and the numbered account

The banknote that crossed the border at Chiasso ended in one of a small number of instruments. The simplest was a deposit account in Swiss francs, opened in the name of the Italian client or in the name of an intermediary. Many clients preferred an account designated by a number or a code word, known in Italian as a conto cifrato or conto numerato. The numbered account was an internal arrangement of the bank. The client's identity was recorded in a file kept by a small circle of senior employees, while statements, internal transfers and the daily processing of transactions used only the number. The arrangement protected the client against indiscretion inside the bank and against the curiosity of employees who might have contacts in Italy. It did not make the account anonymous in law, since the bank always knew the holder and was bound to the same rules of identification and secrecy as for any other account.¹ When the Swiss banks codified their due diligence obligations, they stated expressly that the rules applied "without restriction to accounts, passbooks, securities accounts and safe deposits designated by a number or code".²

The legal protection of the client came from Art. 47 of the Banking Act of 8 November 1934, which made the disclosure of a secret entrusted to a bank officer a criminal offence (Chapter D.I).³ For the Italian client of the 1960s its main value lay in the guarantee against private betrayal, since the Italian State had no legal means of obtaining information from a Swiss bank about a tax or exchange-control matter. A bank employee in Lugano who sold information about Italian clients to the Guardia di Finanza or to an Italian newspaper committed a crime under Swiss law. The same rule also protected the client against the Swiss tax authorities, which played no role for a non-resident. Mutual assistance in criminal matters between Switzerland and Italy was excluded for fiscal and currency offences, which Swiss law placed outside the scope of cooperation, a rule that the Mutual Assistance Act of 20 March 1981 later codified for offences aimed at reducing taxes or violating currency regulations.⁴

The safe deposit box and bearer paper

A second group of clients wanted no account at all. They rented a safe deposit box in a bank or in one of the specialized vaults that opened in Lugano and Chiasso, and kept in it banknotes, gold bars and coins and bearer securities. The safe deposit box gave the bank no knowledge of its contents and kept the client's assets outside the banking records except for the rental contract. Gold had a special place in Italian savings culture. Swiss banks sold bars and coins over the counter, and Italian clients bought them in Lugano and kept them in Swiss vaults or carried them home.⁵

Bearer securities were the third form. Swiss bearer bonds and bearer shares, cash bonds (obbligazioni di cassa, Kassenobligationen) issued by the banks themselves and, from the 1960s, the bearer bonds of the Euromarket offered an investor what Italian shares did not: transferability by delivery and the absence of any register. A Eurobond paid interest without withholding tax on presentation of a coupon at any paying agent. An Italian holder could cut the coupon in Lugano, cash it and leave no record in Italy.⁶ Swiss investment funds and the certificates issued by Swiss banks on Italian securities held in their own names served a similar purpose. They allowed the Italian client to invest in his own country under the cover of a Swiss institution, as in Berbenni's "Operation A", where francs from smuggled lire were reinvested in Italy through certificates of a Swiss bank.⁷

Notes

1. Wikipedia, "Numbered bank account", https://en.wikipedia.org/wiki/Numbered_bank_account (identity "replaced with a multi-digit number known only to the client and selected private bankers"; "the name of the client is still recorded by the bank"), used as a last resort. For the history of banking secrecy see Robert Vogler, Das Schweizer Bankgeheimnis: Entstehung, Bedeutung, Mythos (Zurich 2005). ↩
2. CDB of 28 January 1998, Art. 9 (as above), https://unodc.org/documents/archive/imolin/chbcoc.pdf. ↩
3. Federal Act on Banks and Savings Banks of 8 November 1934 (Banking Act, BankA), SR 952.0, Art. 47 para. 1 lit. a in its current wording (disclosure of a secret entrusted to a person "in seiner Eigenschaft als Organ, Angestellter, Beauftragter oder Liquidator einer Bank"), text at https://www.droit-bilingue.ch/de-fr/9/95/952.0-47-100.html; the provision has been amended in 2009, 2015, 2016 and 2019. See Chapter D.I on the origins and the original wording of the provision. ↩
4. Federal Act on International Mutual Assistance in Criminal Matters (Mutual Assistance Act, IMAC) of 20 March 1981, SR 351.1, Art. 3 para. 3 (no assistance for an offence "which appears to be aimed at reducing fiscal duties or taxes or which violates regulations on currency, trade or economic measures", subject to an exception for duty or tax fraud), English text at https://www.droit-bilingue.ch/de-en/3/35/351.1-3-7.html. ↩
5. On the Italian demand for gold in Switzerland see Segreto (as above). ↩
6. The first Eurobond is usually dated to the issue of 1963 for the Italian motorway company Autostrade, arranged by S. G. Warburg in London: 60,000 bearer bonds of USD 250 each for a loan of USD 15 million at 5.5 per cent, listed in Luxembourg; Wikipedia, "Eurobond (external bond)", https://en.wikipedia.org/wiki/Eurobond_(external_bond), used as a last resort. On the use of Eurobonds by private investors see Youssef Cassis, Capitals of Capital (Cambridge 2006), chapter 6. ↩
7. Berbenni (as above), 336–337, Table 1 (reinvestment in Italy through certificates of a Swiss bank). ↩

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of August 2025.