Hughes

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA 6 UNITED STATES OF AMERICA, Case No. 18-cv-05931-JCS

Plaintiff,

FINDINGS OF FACT AND

v. CONCLUSIONS OF LAW

REGARDING WILLFULNESS

TIMBERLY E. HUGHES,

Defendants.

12 I. INTRODUCTION 1. Plaintiff the United States of America brought this action seeking to enforce civil penalties against Defendant Timberly Hughes, pro se, for failure to report foreign bank accounts by filing a report commonly known as an “FBAR.” The Court held a bench trial by videoconference on June 8 and 9, 2021.1 2. This document addresses the facts of the case and the question of whether the United States has shown “willful” violations of the Bank Secrecy Act’s requirement to file FBARs. Any challenge to the penalty assessed by the United States for such violations is reserved for resolution after further briefing. 3. For the reasons discussed below, the Court finds that Hughes’s failure to file FBARs in 2012 and 2013 was “willful” within the…