Mess with FATCA, and you might face criminal charges. That is one lesson from a five-count superseding indictment charging Panayiotis Kyriacou, Arvinsingh Canaye, Adrian Baron, and Linda Bullock with conspiracies to defraud the United States by obstructing the functions of the IRS in its administration of the Foreign Account Tax Compliance Act (“FATCA”). FATCA requires foreign financial institutions to identify U.S. customers and report information about their financial accounts. FATCA’s primary aim is to prevent U.S. taxpayers from using foreign accounts to facilitate the commission of federal tax offenses. A grand jury had already charged Kyriacou, Canaye, Baron, Bullock with conspiracy to commit securities fraud and money laundering conspiracy, and the superseding indictment adds tax charges.