Barrett, J., dissenting
report.” §1010.350(g)(1). According to the Court, this special rule is a knock against the Government’s reading because it does not require detailed account-level information in such a filer’s initial report. Ante, at 12.
But the Secretary’s accommodation does not advance the Court’s cause. A person with 25 or more accounts still “will be required to provide detailed information concerning each account when so requested by the Secretary or his delegate.” §1010.350(g)(1). And the Secretary’s recordkeeping regulation requires covered persons to retain the same detailed information about each account that otherwise would be reported on the annual form. See §1010.420. So a person with 25 or more accounts violates the BSA for each account with a reporting or recordkeeping problem just the same as a person with fewer than 25 accounts. In both cases, the violation is the failure to report the account properly or to keep records of it.
That consequence is consistent with the statute’s purpose. In arguing otherwise, the Court leans on what the preamble does not say: “[T]hat Congress sought to maximize penalties for every nonwillful mistake.” Ante, at 11. Notably, though, the Court skims over what the preamble does say: that the BSA is designed to “require certain reports or records” that assist the Government in “criminal, tax, or regulatory investigations” and in “intelligence or counterintelligence activities, including analysis, to protect against terrorism.” 31 U. S. C. §5311. When analyzing complex webs of money laundering or funding for international terrorism, knowing about every account matters—and lacking information about 15 accounts is certainly more harmful to law enforcement than lacking information about 1 account. See Brief for United States 38. Given the stated purpose, authorizing a penalty for each undisclosed account makes sense.
Finally, the Court insists that a per-account reading
