The bank said it "proactively contacted" regulators to seek guidance on the trades.
It proactively contacted clients in 2005 to suggest ways to avoid a new tax levied on the Swiss savings accounts of EU citizens, a measure brought in through a treaty between Switzerland and the EU to tackle secret offshore accounts.
"The PCC proactively contacted representatives of Mr Gately's family shortly after his death to ensure that they were aware of the PCC's services should they wish to use them".
The documents show for the first time that rather than acting as a passive party to the tax schemes of its clients, HSBC Suisse proactively contacted clients to market techniques that would have effectively sabotaged the tax treaty deal.
Five young American Muslims were arrested in Pakistan for attempting to join a terrorist group after the children's parents and Muslim American community members proactively contacted the FBI and assisted in their investigation (although the five have since protested their innocence).
The bank proactively contacted clients in 2005 to suggest ways to avoid a new tax levied on the Swiss savings accounts of EU citizens, a measure brought in through a treaty between Switzerland and the EU to tackle secret offshore accounts.
All customers who purchased the counterfeit products have been proactively contacted by Groupon notifying them of the recall and have been advised to discontinue use immediately, dispose or return the goods, and seek professional medical advice if they have concerns about their health".
At issue is whether Mr. Craig proactively contacted Mr. Sanger to provide and promote the report, which could fall under the public relations prong of FARA, or merely responded to inquiries from The Times and other media outlets about Skadden Arps's analysis.
These days, it's almost certain that a reporter or analyst will, in the best case, see and file the release but most often, the very people we hope will find and in turn, report on the information discovered, will honestly never know that you released news at all unless they're proactively contacted.
