Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 18 of 37
| Payee | Transaction Date |
Originating Account Holder |
Country of Origination |
Amount of Transaction |
| Bade LLC United States Bank Account E |
11/25/2014 | Global Endeavour Inc. | Grenadines | $120,000 |
| 2014 Tax Year Total | $289,112 | |||
MANAFORT And GATES’ Hiding Foreign Bank Accounts And False Filings
19. United States citizens who have authority over certain foreign bank accounts—whether or not the accounts are set up in the names of nominees who act for their principals—have reporting obligations to the United States.
20. First, the Bank Secrecy Act and its implementing regulations require United States citizens to report to the Treasury any financial interest in, or signatory authority over, any bank account or other financial account held in foreign countries, for every calendar year in which the aggregate balance of all such foreign accounts exceeds $10,000 at any point during the year. This is commonly known as a foreign bank account report or “FBAR.” The Bank Secrecy Act requires these reports because they have a high degree of usefulness in criminal, tax, or regulatory investigations or proceedings. The Treasury’s Financial Crimes Enforcement Network (FinCEN) is the custodian for FBAR filings, and FinCEN provides access to its FBAR database to law enforcement entities, including the Federal Bureau of Investigation. The reports filed by individuals and businesses are used by law enforcement to identify, detect, and deter money laundering that furthers criminal enterprise activity, tax evasion, and other unlawful activities.
21. Second, United States citizens also are obligated to report information to the IRS regarding foreign bank accounts. For instance, in 2010, Schedule B of IRS Form 1040 had a “Yes” or “No” box to record an answer to the question: “At any time during [the calendar year], did you have an
interest in or a signature or other authority over a financial account in a foreign country, such as a
18
