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By contrast, Credit Suisse paid $2.5 billion to settle its U.S. tax investigation – nearly four times UBS' fine five years previous. The bank also got dinged for its «inadequate cooperation» by the lead U.S. attorney prosecuting the case, which led authorities to elicit a guilty plea from Credit Suisse.

To be sure, UBS is innocent until definitively proven guilty after exhausting all appeals it elects to take. It is nevertheless noteworthy that Diethelm and Ermotti, after years of submissiveness, have adopted a feisty tone towards France.

Diethelm marshaled the crème de la crème of French judicial expertise as well as his in-house trial lawyers for the French proceeding. He even went out on a limb politically, telling a French daily that, effectively, other banks could reject the city as a Brexit haven if the Paris judge ruled against UBS.

Question of Honor

Diethelm's pugnaciousness suits Ermotti perfectly: the CEO said two years ago he wouldn't permit UBS to settle if it saw its honor besmirched.

«We can only do a settlement when we believe the facts that lead to a settlement are accurate enough to entertain a resolution of the matter and in order to protect our reputation,» Ermotti said. He made the comments just weeks after France rolled out a procedure,  called «convention judiciaire d'intérêt public», or CJIP, which was meant to allow the bank to reach a settlement with neither a trial nor an admission of wrong-doing.