The U.S. Supreme Court on 28 February 2023 issued its ruling in a case dealing with the penalties due for violations of the reporting obligations under the Bank Secrecy Act (BSA) and its implementing regulations. The BSA requires U.S. persons with (an interest in) foreign bank accounts to annually file with the IRS a Report of Foreign Bank and Financial Accounts (FBAR). Failure to file the FBAR non-willfully attracts a maximum penalty of USD 10,000. The case before the Court concerned a dual U.S. and foreign country citizen who learned of his FBAR obligations in 2011 upon returning to the...