Taxpayers can take advantage of voluntary disclosure opportunities if they have offshore accounts that they have not properly reported. By participating in disclosure programs including the Offshore Voluntary Disclosure Program (OVDP) for foreign bank accounts, it is possible to limit penalties and avoid criminal prosecution. 

The Offshore Voluntary Disclosure Program (OVDP) limits the penalties faced by taxpayers who failed to file the Report of Foreign Bank and Financial Accounts (FBAR). FBAR must be filed every year by any U.S. citizen who has offshore accounts, even if the citizen is living abroad in the country where the account is held. There is a streamlined OVDP procedure, but unfortunately early indicators suggest that very few people will be found to be eligible.