FinCEN Form 114 is a form that must be filed by certain U.S. connected persons who have an offshore account or who have signature authority on any kind of offshore account. FinCEN Form 114 may be better known as a Report of Foreign Bank and Financial Accounts (FBAR). The form must be filed annually by those who have accounts that must be reported.

In 2008, the idea was formed for a program in which Swiss Banks could avoid criminal prosecution for the bank's role in facilitating the evasion of U.S. taxes. The goal was to catch U.S. affiliated individuals who had funds offshore they were not declaring. The U.S. and Swiss governments negotiated on how to structure efforts to fight tax evasion, and in 2013, the Swiss Bank Program launched.

If you have offshore funds at a Swiss bank account, the United States government wants to know about your account and about the money within it. You must file an annual Report of Foreign Bank and Financial Accounts (FBAR) and could face serious penalties if you don't, especially if the IRS believes you willfully failed to disclose your offshore account.

The Department of Justice Tax Division has been aggressively cracking down on those who evade their tax obligations. One of the DOJ's main focuses has revolved around identifying people who fail to declare offshore funds.  U.S. authorities have been making deals with banks to obtain information on accountholders and have created amnesty programs with the goal of getting certain violators to come forward and report previously undeclared offshore accounts in exchange for reduced penalties and avoiding criminal charges.

In 2015, more than $10 billion of transactions took place using Bitcoin. Bitcoin is a virtual currency and its use has been increasing, especially after the IRS began cracking down on offshore accounts. The increased use of Bitcoin has not escaped the notice of the IRS, though.