Original Compliance Risk Determination for Streamlined‏

The risk level may rise if any of the following are present:
•If any of the returns submitted through this program claim a refund;
•If there is material economic activity in the United States;
•If the taxpayer has not declared all of his/her income in his/her country of residence;
•If the taxpayer is under audit or investigation by the IRS;
•If FBAR penalties have been previously assessed against the taxpayer or if the taxpayer has previously received an FBAR warning letter;
•If the taxpayer has a financial interest or authority over a financial account(s) located outside his/her country of residence;
•If the taxpayer has a financial interest in an entity or entities located outside his/her country of residence;
•If there is U.S. source income; or
•If there are indications of sophisticated tax planning or avoidance.”

http://www.irs.gov/uac/Instructions-for-New-Streamlined-Filing-Compliance-Procedures-for-Non-Resident-Non-Filer-US-Taxpayers

 As a general rule, I think entering OVDP when you know you'll opt out is undesirable if the determination is made that there's no material criminal exposure. It guarantees substantial legal fees and an audit, which might not otherwise occur. If I feel confident that I'd demonstrate non-willfulness in an opt-out audit, I'd probably feel roughly as confident that I can demonstrate non-willfulness if I'm audited following a QD. Of course, it is possible that the IRS looks at you in a someone more favorable light if you join OVDP and opt out (who knows? We're talking psychology here), but in principle the IRS should consider all of the facts surrounding the noncompliance at the time of the noncompliance. Those facts are whatever they are, and shouldn't be affected by subsequent events, such as the choice to not join OVDP (which ought not be held against anyone, as there's no legal or moral obligation to do so).