Page:Bittner v. United States.pdf/4

Syllabus

nonwillful violators—avoided by reading the nonwillful penalty to apply on a per-report basis.

The government replies that the per-report interpretation risks the anomaly that the Secretary could formulate reporting requirements to require a separate report for each account and in that way effectively achieve a per-account penalty for nonwillful violations. What this proves is unclear, as the Secretary’s discretion to require more (or fewer) reports is not at issue here, and in any event does not answer whether the Secretary may impose nonwillful penalties on a per-report or per-account basis. Pp. 9–14.

(c) Best read, the BSA treats the failure to file a legally compliant report as one violation carrying a maximum penalty of $10,000. P. 16.

19 F. 4th 734, reversed and remanded.

Gorsuch, J., announced the judgment of the Court, and delivered the opinion of the Court except as to Part II–C. Jackson, J., joined that opinion in full, and Roberts, C. J., and Alito and Kavanaugh, JJ., joined except for Part II–C. Barrett, J., filed a dissenting opinion, in which Thomas, Sotomayor, and Kagan, JJ., joined.