In Re GRAND JURY PROCEEDINGS, NO. 4-10

HULL, Circuit Judge:

This appeal concerns a grand jury investigation and the issuance of subpoenas duces tecum to a target (the “Target”) and his wife, which required the production of records concerning their foreign financial accounts. The Target and his wife refused to comply with the subpoenas by producing their records, asserting their Fifth Amendment privilege against self-incrimination. The government moved to compel, pointing out that the Supreme Court has recognized an exception (the “Required Records Exception”) to the self-incrimination privilege when certain records are kept…