The FT has noted that Dave Hartnett, HM Revenue & Customs Director General is putting pressure on foreign owned banks working in the UK and the Crown Dependencies to cooperate with his authority by disclosing full details of bank accounts held offshore by their customers resident in the UK.

Quite right to, but as ever its the lawyers who see a problem. The FT reports that:

Jason Collins, a partner at McGrigors, the legal firm, said banks were being asked to submit to the Revenue's process before they had been given evidence that some of their clients were noncompliant. "The banks are in a very difficult situation."

No they are not. They are being asked to operate openly, honestly and accountably. In the process they are being asked to decide between protecting customers who have may have pursued criminal activity or to fulfil their obligations to the society that his given them their licence to operate.

What's difficult about that, Jason? Come to that, is there a choice on the table?