"Offshore Accounts in the Bullseye: IRS Targets Customers at 20 More Swiss Banks"

If any of your clients have undisclosed offshore accounts, simply filing delinquent foreign bank account reports may subject them to large civil penalties— up to the greater of $100,000 or 50% of the account value for each year in which the form wasn't filed —in addition to criminal prosecution.  Approach such situations with caution.