Multiple accounts and multiple FBAR penalties‏

In many cases multiple accounts are an indication of legitimate reasons for having foreign accounts. Just like I have multiple accounts in the US for multiple reasons and purposes, such may be the case with foreign accounts. Keep in mind that the more foreign accounts you have, the more chances of one account becoming known, so it seems that if secrecy is your goal you would want one account, not many.
Also as far as the IRM it says that multiple penalties per year (ie per-account) should be limited to egregious cases. In my view egregious conduct would be to establish various offshore companies and accounts so transfers are smaller and more likely to have a justifiable purpose, then churn the money through a daisy chain of accounts in different banks, countries and company names to obscure the trail; in other words a typical money laundering scheme. Merely having multiple accounts does not fit this description.

Example of reasonable cause : We have no other formal structures, corporations, trusts, foundations or entities affiliated with any of the accounts. The nature of all accounts are simply joint , with no power of attorneys, parent, entity or corporate account holders. We do not have or participate in any exotic investment instruments like credit default swaps, offshore hedge funds, offshore feeder funds, offshore master funds, offshore money laundering funds, PFICs, or special purpose investment vehicles (SIVs). In other words, our financial arrangements are plain vanilla for ordinary people living fairly ordinary lives overseas with standard checking accounts and we do not even have a savings account.
With regards to the ``foreign accounts`` we always had a legitimate purpose for establishing -like receiving local salary payments- and even maintaining the accounts and interest income when earned was always reported on Form 1040 . All accounts were opened as part of a normal, lawful residence and activities in these countries .

FBAR filings go to Treasury and the only way the IRS would have known about FBAR would have been to 1) have a reason to query Treasury in Detroit then 2) actually query. I am basing this on what's been reported publicly. It would be much easier for the IRS to spot those answering YES at the bottom of Schedule B for the first time, or those filing 8938 for the first time in future years.
            The IRS administers the FBAR filings pursuant to an agreement between the IRS and Treasury. So, in that administration, it would be easy for the computer to find a first time filer (or even a not recent filer) for purposes of determining whether to do an FBAR audit. Now, when it is or gets combined with an income tax audit, I think there are some extra internal steps that must be covered because of Section 6103.
          The FBARs are filed with the IRS Enterprise Computing Center in Detroit. The mailing is to "U.S. Department of the Treasury, P.O. Box 32621, Detroit, MI 48232-0621," but that zip code is to the IRS Enterprice Computing Center in Detroit.

FBAR penalties should not be used to extract penalties for income tax underpayments that are in excess of the penalties that Congress specifically provided for income tax underpayment. The income tax penalty at worst would be 75% of the tax due (civil fraud), but the FBAR penalties (particularly if multiple year) can exceed 500 % of the tax due. No FBAR penalty where the FBAR violation arose solely from avoiding the income tax, because the income tax penalties should only apply. I would impose the tax and income tax penalties and a much lighter FBAR penalty with a warning letter that should it happen again stiffer penalties would apply.
 http://taxlitigator.me/
 http://www.irs.gov/Individuals/International-Taxpayers/Offshore-Voluntary-Disclosure-Program-Frequently-Asked-Questions-and-Answers