The Financial Crimes Enforcement Network (FinCEN) of the US Department of Treasury issued final regulations under the Bank Secrecy Act (the “BSA”) in February of 2011 with respect to the “Report of Foreign Bank and Financial Accounts” (FBAR). The final regulations replaced proposed regulations published in 2010.1 They are effective for FBAR filings for calendar year 2010, which are due no later than June 30, 2011, and for reports required to be filed for all subsequent years. In addition, the final regulations permit any person who, pursuant to IRS notice 2010-23, properly deferred filing an FBAR for years prior to 2010, to apply the provisions of the final regulations for purposes of determining their filing requirements for reports due June 30, 2011, for such prior years. The IRS also recently issued a revised FBAR form and instructions intended to reflect the changes made by the final regulations. In our May 27, 2010 Legal

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