The simple answer is Panama.  Panama has strong banking privacy laws backed by jail time as do other offshore jurisdictions.  The difference is that Panama actually enforces its banking secrecy laws.  In fact, Panama has been so vigilent in enforcing its banking privacy laws, that this writer cannot think of any examples where banking secrecy was lifted, except in major criminal cases.  On the other hand, for other jurisdictions like the Cayman Islands and Belize, we know of several examples of serious violations of offshore banking secrecy law without any reprocussions to the violator.   The law means nothing if it is not enforced.  To be a good jurisidction to open an offshore bank account, it must first and foremost enforce its secrecy laws.  Panama is the only offshore banking jurisdiction that we feel meets all of the above criteria including strong banking secrecy laws that ARE STRONGLY enforced.