Reporting Requirements for Foreign Financial Accounts: FinCEN Releases Notice Delaying Deadline to June 30, 2012 for Certain Signature Authority Filers

Sullivan & Cromwell LLP - May 31, 2011

The Financial Crimes Enforcement Network of the Department of the Treasury (“FinCEN”) today released Notice 2011-1 (the “Notice”), extending by one year the June 30, 2011 deadline for filing a Report of Foreign Bank and Financial Accounts (or an “FBAR”) for certain individuals with signature authority over, but no financial interest in, a foreign bank or other financial account of a subsidiary of their employer, a parent of their employer, or another member of their 50-percent controlled group if one of the entities in the controlled group qualified for an exemption from FBAR reporting.