
District court: FBAR non-willful penalty applies per report, not per account
A U.S. District Court recently concluded that the penalty for a non-willful violation of the rules relating to FinCEN Report 114, “Report of Foreign Bank and Financial Accounts” — commonly referred to as an FBAR — applies to each report rather than to each foreign financial account maintained but not timely or properly reported. Let’s take a closer look at the details.