ZWERNER CASE UNLIKELY TO PROVIDE CONSTITUTIONAL REVIEW OF 50% FBAR PENALTY

The Zwerner case has been discussed here and here. Many hoped that this case may give rise to judicial review of whether the 50% per year FBAR penalty for willful violations passes muster on U.S. Constitution limits on excessive fines. That no longer appears likely as the government and the defendant have now settled the pending litigation regarding that penalty.