United States v. Richard Rund

Summary

The Fourth Circuit affirmed the district court’s summary judgment, holding that Richard Rund’s FBAR violations were willful as a matter of law and that the $2.9 million civil penalty did not violate the Excessive Fines Clause of the Eighth Amendment. The court applied the Horowitz standard for willfulness and found the penalty proportionate under the Bajajian proportionality test.