In Bittner v. United States, 598 U.S. ____ (2023), the U.S. Supreme Court held that the penalty for the nonwillful failure to file a Report of Foreign Bank and Financial Accounts (FBAR) is $10,000 per report rather than per account. “Best read, the BSA treats the failure to file a legally compliant report as one violation carrying a maximum penalty of $10,000, not a cascade of such penalties calculated on a per-account basis,” Justice Neil Gorsuch wrote on behalf of the majority.
