I'm a Swiss citizen living in Switzerland (and not an "American person" in whatever definition of this dubious term). And as such I just don't understand why Swiss banks should enter ANY American program. After all they are subject to Swiss laws and jurisdiction and not American ones. Of course they are fearing repercussions against their American businesses, assets, licenses etc. But if the the 10 - 15 major European banks had declared TOGETHER that they are not playing the American game, what would the US have done? Stop the transatlantic money transfer altogether?