Carlton Greene

Apr 15, 2024 | law360.com | Carlton Greene |Caroline Brown |Nicole Succar

ADVERTISEMENT Don't want ads? Subscribe or login now. By Carlton Greene, Caroline Brown and Nicole Succar (April 15, 2024, 5:09 PM EDT) -- On March 29, the U.S. Department of the Treasury's Financial Crimes Enforcement Network, issued a notice and request for information and comment,[1] or RFI, seeking comments on the Bank Secrecy Act's customer identification program rule....

Mar 6, 2023 | lexology.com | S. Marshall |Carina C. Federico |Carlton Greene |Samantha Skabelund

In 2021, two Circuit Court of Appeals, held diametric positions regarding penalties for taxpayers who non-willfully failed to file a Report of Bank and Financial Accounts (FBAR): The Ninth Circuit concluded that the penalty was $10,000 per untimely filed FBAR, while the Fifth Circuit concluded that the penalty was $10,000 per account on each untimely filed FBAR.