Daniela Dadurian is facing a USD2.7 million liability for failing to file Foreign Bank Account Reports (FBARs) for accounts owned by herself, her mother, and several foreign entities after she failed to convince a Florida district court that there is no evidence that her omissions were wilful. Dadurian argues that she relied on her tax attorneys to handle her affairs, but the US Department of Justice now considers that this 'reasonable cause' plea should no longer be considered a defence to penalties for wilful non-disclosure, as some courts have already accepted in the Kimble and Horowitz cases.