Under the federal Bank Secrecy Act (BSA), U.S. taxpayers who own qualifying offshore accounts and other foreign financial assets are required to file a Report of Foreign Bank and Financial Accounts (FBAR) on an annual basis. Failure to comply with the BSA can lead to steep penalties—even if the failure is inadvertent. With this in mind, U.S. taxpayers who discover that they are behind on their FBAR filings must take proactive steps to come into compliance. As Washington D.C. international tax attorney Kevin E. Thorn, Managing Partner of Thorn Law Group, explains, this may mean submitting a statement of “reasonable cause.”