OVDP is more reasonable. Eight years of back taxes with penalties and interest. A reduced FBAR penalty - 27.5% of highest balance over eight years (50% if you used the wrong bank). No criminal charge. No prison time. The window closes on OVDP on September 28th.
Under current law, U.S. taxpayers must report certain offshore assets. Each "US person" with an interest in, signature or other authority over, one or more bank, securities, or other financial accounts in any foreign country must file a Report of Foreign Bank and Financial Accounts (more commonly, FBAR) if the aggregate value of such accounts at any point in a calendar year exceeds $10,000.
Undisclosed foreign accounts or income can trigger big civil penalties, conceivably even criminal prosecution. Since 2009, many foreign accounts and income came within the IRS's enormous offshore enforcement efforts. Nearly 10 years on, not everyone has entered the IRS Offshore Voluntary Disclosure Program (OVDP). The program is closing, but there is still time to get in under the wire.