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A Swiss bank account no longer offers the ironclad protection it used to. Embarrassed by its image as the banker of choice for Third World tyrants and organized criminals, over the past decade Switzerland has introduced a raft of legislation designed to clean up its status as a financial haven, including anti-money-laundering laws that are among the toughest anywhere. The country now routinely cooperates in international criminal cases and has taken major steps after Sept. 11 to help track the financing of terrorism.

But on one issue Switzerland has remained unyielding: tax evasion by nonresidents. If a German dentist or a French entrepreneur has an account in Zurich or Geneva and doesn?t declare the interest back home, the Swiss say that?s not their problem. It?s an attitude that has long infuriated Switzerland?s neighbors. Now it is hurtling the country toward a head-on collision with the European Union that threatens to frustrate efforts to improve Switzerland?s international image?and could spell the end of its fabled banking secrecy once and for all.

At the heart of the dispute is an E.U. directive, finally agreed to last year after more than a decade of work, that aims to curb tax evasion through an exchange of tax information among member states. Prompted by Luxembourg and Austria?two tax havens within the E.U. that are particularly concerned about a flight of capital from their banks?Brussels is asking the Swiss to help out. It wants Switzerland, which is not an E.U. member, to automatically provide information to tax authorities about bank accounts held by E.U. residents.

To judge from the reaction in Switzerland, complying with the demand would be like giving away the Alps. "We won?t allow ourselves to be crushed by the weight of the E.U.," says Hans Kaufmann, a former bank economist and the Swiss member of the parliament spearheading a move to add banking secrecy to the constitution as a fundamental right. The proposal by his Swiss People?s Party is now working its way through parliamentary committees, but already it has won significant support. Two cantons, Zurich and Aargau, have voted to back the initiative, and several other cantons are considering throwing their weight behind it too. With polls conducted earlier this year showing that three in four Swiss support banking secrecy, any attempt to persuade the citizens to lift it "doesn?t stand a ghost of a chance," President Kaspar Villiger told a meeting of the Swiss Employers? Association in June?though other polls suggest there may be some movement in public opinion.

What makes this last stand of Swiss banking secrecy particularly intriguing is the clash between morality and money, as well as the underlying geopolitics. On the one hand, many Swiss see secrecy as a cornerstone of the nation?s prosperity, something that gives Switzerland an edge in the competition among global financial centers. The Swiss are world leaders in managing cross-border private wealth, holding more than a quarter of the total assets parked by residents of one country in another. (Use the word offshore to a Swiss banker and you?re liable to get a half-hour lecture on why Switzerland is not an offshore financial center?mostly because the term offshore is ill-defined and mildly pejorative, associated with a lack of regulation.)

On the other hand, despite the recent cleanup efforts, the continuing adherence to secrecy leaves Switzerland vulnerable to the accusation that it has something to hide?a charge that makes the Swiss cringe. And despite a historic reflex dating back to William Tell to thumb their noses at the outside world, the Swiss realize they need to maintain good relations with the E.U., which completely surrounds them and accounts for about two-thirds of their trade. "It?s not in our long-term interest to profit from any loopholes," says Urs P. Roth, chief executive of the Swiss Bankers? Association, who nonetheless adds: "I don?t see why we should adopt a system with which we aren?t familiar."

At the first round of talks on the issue in June, the Swiss told the E.U. that an information exchange was out of the question, and offered an alternative proposal. While unwilling to pass on bank account details, Switzerland would be prepared to levy a withholding tax on the bank accounts of E.U. residents. This would safeguard client privacy, but still provide European treasuries with tax revenue. "We think it?s a most unique offer," says Gregor Kündig, an executive member of the national industry federation Economiesuisse who deals with E.U. issues. "It has never happened in history that we collected taxes for other states."

Unprecedented, perhaps, but still unacceptable to Brussels. E.U. officials say the withholding tax would pose significant bureaucratic problems as member states try to figure out who should receive how much of the money that is withheld. Politically, it?s just not enough for Luxembourg and Austria.

The talks resumed on Sept. 3 after a summer recess, but a war of words was heating up before that date. German Finance Minister Hans Eichel publicly reprimanded Switzerland at the E.U.?s Seville summit in June, saying it was unacceptable for any nation to make a living as "a safe haven for tax evaders." A British treasury minister, Paul Boateng, has attacked Swiss banking secrecy as an obstacle to fighting terrorism. And E.U. officials say privately that they expect pressure on Switzerland to build this fall as more politicians direct the spotlight toward Swiss morals. "The Swiss will inevitably be portrayed as profiting from the proceeds of what everyone else thinks of as a crime," says a senior official closely involved in the discussions. Quips Michel Y. Dérobert, secretary-general of the Swiss Private Bankers? Association in Geneva: "We?ve left the field of taxation to enter the field of wild politics."

As students of recent Swiss history can attest, international public pressure?especially when it relates to moral issues?can be highly effective in lifting banking secrecy. A long-standing tradition dating back to the Middle Ages, secrecy was codified into Swiss law in 1934, just as Hitler was consolidating his power in Germany, Stalin was purging his opponents in the Soviet Union and a clenched fistful of dictators were strutting around other European countries. By law, bankers who breach client confidentiality today face up to six months in jail and a fine of up to $33,000.

With secrecy came abuse. The Swiss themselves were so startled by revelations in 1977 about rogue activities at the Chiasso branch of Credit Suisse?whose managers allegedly funneled funds through an offshore trustee company, hiding losses from their supervisors?that a new age of tougher bank regulation was ushered in. First came due-diligence rules that compelled banks to identify all their clients and establish the beneficial owners of assets. For over two decades now, banks have been obliged to keep a copy of some official identification of a client, like a passport?a measure that U.S. banks are only now starting to adopt as part of the post-Sept. 11 fight against terrorism.

The fall of Ferdinand Marcos, the corrupt former President of the Philippines, led to the first major break with the secrecy tradition. Under enormous worldwide pressure, the Swiss in 1986 froze accounts belonging to Marcos, and later transferred more than $600 million into an escrow account in Manila. The case marked the start of Swiss cooperation in international criminal cases and the advent of tough laws against money laundering. Any suspicions of money laundering must now be reported to a central monitoring agency in Bern. Strict rules hold senior bank managers accountable for the accounts of politicians, whatever country they come from.

In two recent cases the laws brought striking results. Banking regulators publicly reprimanded several Swiss banks?by name?for keeping accounts belonging to relatives of the former Nigerian dictator Sani Abacha. And it was the Swiss in the autumn of 2000 who tipped off Peru that Vladimiro Lenin Montesinos Torres, the former head of Peruvian intelligence, had stashed away about $114 million in five Swiss accounts. Judicial authorities in Zurich blocked the accounts after the banks themselves reported their suspicions. The Swiss ambassador in Lima then informed the Peruvian government and urged it to open an international criminal investigation, with which Switzerland cooperated. In addition, it was fierce international pressure that led the Swiss to disclose information about thousands of dormant accounts belonging to victims of the Nazis?and to pay $1.25 billion in 2000 to settle class actions relating to those accounts.

Taxing savings is less of a headline-grabbing issue than the money of fallen dictators or Holocaust victims, but for the E.U. it may be just as significant. The planned exchange of tax information would create the beginnings of a more unified pan-European fiscal system, and end the anomaly of tax havens within the E.U. Germany in the 1990s saw how damaging capital flight could be when it instituted a special withholding tax on savings to pay for reunification, sparking an exodus of billions of marks to neighboring Luxembourg. Tax evasion is not a criminal offense in Switzerland, and the Swiss say they have good systems for preventing it at home: they levy a hefty 35% withholding tax on dividend and interest income for their own citizens.

Along Zurich?s Bahnhofstrasse, home to the nation?s biggest banks and priciest jewelers, nerves are fraying. These are tough times for the Swiss financial services sector, which accounts for more than 10% of the nation?s gross domestic product and approximately 6% of jobs. The long slide of world stock markets is taking its toll on profitability and forcing bankers to work particularly hard to calm their well-heeled clients. Swiss banks have also borne the brunt of a successful tax amnesty mounted earlier this year by Giulio Tremonti, Italy?s Finance Minister. Italians repatriated assets valued at j52 billion, paying a symbolic 2.5% fine in exchange for immunity. Much of the total was pulled out of Switzerland; j10.6 billion came from just one Swiss bank, UBS (although the bank says almost half of that money was moved to branches it has opened in Italy).

From the perspective of their boardrooms, bankers are hopeful the current storm will blow over. "If we were being really hard in this negotiation, we?d say to the E.U. that it?s not our problem," says Dérobert of the private bankers? association. "If it?s just a question of abolishing something that we hold dear in order to help the competition, we?re not interested." Says Thomas Baer, chairman of Bank Julius Baer: "German banks, as all banks, are not in as good a shape as they were, and they?d welcome any opportunity to go against their competition."

Down at street level, the view is less confident. "Banking secrecy is an old tradition in Switzerland, but in the end Switzerland will have to adapt itself to the E.U.," says Otto Boesch, a retiree from St. Gallen, checking his stocks on a big board outside the Bahnhofstrasse headquarters of UBS. Concurs Marc Weber, who works nearby in a bank he won?t name: "Switzerland can?t isolate itself. We can?t survive as a fortified island in today?s world. It?s just a question of time."

Still, many Swiss are bracing for a fight. In a front-page editorial on Aug. 1, Switzerland?s national holiday, the Neue Zürcher Zeitung went so far as to liken the E.U. information-exchange measures to the all-intrusive Big Brother state of George Orwell?s novel 1984. And Gregor Rutz, general secretary of the Swiss People?s Party, which is pushing the constitutional amendment, contends that banking secrecy "is not at all anachronistic. It?s a highly modern policy that is particularly important today at a time when we experience ever more state intervention in the private lives of citizens." Brussels, are you listening?

• PETER GUMBEL/Zurich
• The Swiss banking industry is trying to improve its image. But it still wants to keep mum about accounts held by European Union residents