I have had multiple of these.  In EVERY time I have worked with a tax attorney to get the client up-to-date. Why, because this starts with the Criminal Division, not the Civil. There used to be a streamlined provision that the penalties could be reduced.  See https://www.irs.gov/individuals/international-taxpayers/delinquent-fbar-submission-procedures but the IRs requests 3 years of amended returns and 6 years of FBAR's. There is too much at risk (malpractice wise) for you not to consult a tax attorney on this.