FinCEN Form 114—I’m Not the Criminal Here

FinCEN Form 114, Report of Foreign Bank and Financial Accounts, is a mandatory report to the U.S. Treasury Department. It is not connected, directly at least, with payment of income tax. My accountant tells me that failure to file each year can result in serious penalties, and I have confirmed that he is not joking. Many real crimes bring forth much lighter penalties from the government.
Think about this, however. It is not a crime to have a foreign bank account or other foreign financial account. So, the U.S. government is threatening to punish—and, I presume, sometimes actually punishing—people who merely

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