The tax penalties and fines for US expats for not filing FBARs are much stricter and tougher than the failure-to-file or failure-to-pay ones. Expat willful violation means that you knew you had to file but decided not to. Non-willful, on the other hand, means that you weren’t aware of the requirement to file FBAR and, therefore, unintentionally failed it. The minimum penalty you may face for non-willful violation is $10,000 for each year that you fail to file FBAR. If the IRS considers the failure to file as willful, then the penalty will be $100,000 or 50% of the account balance at the time of the violation, whichever is larger.