The IRS along with the DOJ has been aggressively pursuing offshore account holders to disclose their overseas bank accounts before it's too late.  There are significant penalties for holding accounts in certain foreign banks.  However, in an effort to encourage account holders to disclose their accounts, the IRS started the Offshore Voluntary Disclosure Program (OVDP)  and the streamlined procedures enable taxpayer to meet their tax obligations while limiting the potential penalties for continued non-compliance.