There are both civil and criminal penalties for failure to file  a Foreign Bank Account Report 90-22.1 (FBAR). The criminal tax penalties can result in a fine of not more than $ 250,000, or five years in prison, or both. 31 U.S.C. 5322(a). For willful violations occurring prior to October 23, 2004, a civil penalty equal to the greater of  the balance in the account at the time of the violation (not to exceed $100,000) or $25,000.

For willful violations occurring after October 22, 2004, the maximum civil penalty is increased to the greater of $100,000, or 50 percent of  the balance of the account at the time of the violation. 31 USC 5321(a)(5).