The Stakes
FBAR penalties are civil penalties set by statute and adjusted for inflation. Willful penalties can be measured as a percentage of the account balance, which is why these cases get expensive fast. The IRS and DOJ are actively pursuing foreign account cases.
The Fix
The Streamlined Filing Compliance Procedures offer reduced penalties (5% or 0% for overseas residents) for non-willful non-filers. File amended returns for three years and FBARs for six years. Do this before the IRS contacts you.
Foreign account penalties are the most severe in the tax code. The remediation programs are the most generous. The window to use them is still open.
This guide is general information about federal tax law, not legal advice for your situation. Reading it does not create an attorney-client relationship.