As of: 1/15/21 10:33 AM
Received: January 14, 2021
Status: Non_Public
Tracking No. kjx-ic1s-qfnv
Comments Due: January 15, 2021
Submission Type: Web

Docket: FINCEN-2020-0013
Agency Information Collection Activities; Proposed Renewal; Comment Request; Renewal Without Change of Reports of Foreign Financial Accounts Regulations and FinCEN Report 114, Report of Foreign Bank And Financial Accounts

Comment On: FINCEN-2020-0013-0001
Agency Information Collection Activities; Proposals, Submissions, and Approvals: Renewal Without Change of Reports of Foreign Financial Accounts Regulations and FinCEN Report 114, Report of Foreign Bank and Financial Accounts

Document: FINCEN-2020-0013-DRAFT-0029
Comment on FR Doc # 2020-25216

Submitter Information

Name: Anonymous Anonymous

General Comment

First of all, thank you for offering this chance to provide comments and feedback.

Many others have already shared stories of frustration and hardship that this program has caused for US citizens that live abroad. I agree with many of the comments - as a US/Canadian dual citizen, I've also experienced the same confusion, frustration, and massive accounting firm fees involved in filing FBAR and US taxes. But if FBAR was a truly effective program and a good use of US Government resources, I would gladly support it even if it personally causes me inconveniences. My concern is that FBAR does not seems to be an effective or efficient way to actually uncover financial crimes - in fact, FBAR may inadvertently allow more financial crimes to occur undetected by consuming FinCEN resources and attention that should be focused elsewhere.

Admittedly I'm not an expert in this area, but through my career as a technology consultant, I've worked with several compliance and enforcement branches of public sector agencies, including units that investigate financial integrity of organizations and individuals to ensure that their funding is not sourced through organized crime, money laundering, etc. Those agencies have leveraged modern digital systems, analytics, and intelligence gathered through close partnerships with other law enforcement agencies to uncover financial crimes. I've never encountered an approach to financial integrity investigation as simplistic as the FBAR program, or as broadly and crudely applied to a huge number of private citizens with no criminal connections. I worry that FBAR is simply diverting energy from FinCEN staff that would be better spent discovering real crimes and coordinating with other US departments and global agencies. I highly recommend that FinCEN consider a more modern, effective, and efficient way to fight financial crime, while also reducing the reporting burden on hard working US citizens.

Thanks again for this opportunity to provide my perspective.