In a major win for folks with international accounts that may have forgotten to report them, on February 28, 2023, the Supreme Court held that the Bank Secrecy Act’s $10,000 maximum penalty for the non-willful failure to file a compliant report should be calculated per report, not per account. This is a critical change because previously folks were charged per account, even if their failure to report was non-willfull, or due to a mistake or lack of knowledge. Ten thousand dollars may still seem like a lot but it is vastly less than previously when the penalty was per account.

Supreme Court Rules In Taxpayer’s Favor On FBAR Penalties (