Correct Defective Returns that Go Back Beyond the Most Recent 3 Tax Years

Use the SDOP to correct your troubled tax returns relating to the most recent three tax years (i.e., 2011 through 2013) while filing amended tax returns to correct the more troubled tax returns relating to tax years 4 through 6 (i.e., 2008 through 2010).
Assuming that the streamlined submission is successful, the taxpayer would only be liable for an offshore penalty equal to 5% of the highest aggregate value of certain foreign assets. The five-percent penalty is in lieu of the failure-to-file and failure-to-pay penalties, the accuracy-related penalty, the information return penalty, and the FBAR penalty. Therefore, at first blush, going streamlined makes all the sense in the world.
However as we know this option has a major shortcoming. Because the streamlined procedures only cover the most recent 3 tax years when it comes to U.S. tax returns and not any earlier years, there is still the uncertainty of what could happen in tax years 2008, 2009, and 2010. Might the IRS assert onerous civil penalties? Might the IRS refer the case to CI for investigation or, worse yet, to the Department of Justice with a recommendation for prosecution ?

I have noticed on the web that currently many tax attorneys write in their blog posts about that the "willful FBAR penalty can be piled up like a stack of bricks, one on top of the other, as far as the eye can see" and that one could be looking at 50% of the highest balance (which is wrong btw.). I am again a bit reminded of the times in 2010 to 2012 where the compliance industry was mainly interested in "fear mongering" and rounding up their "clients" to be processed as fish fertilizer . Keep in mind it is not realistic to assume what the IRS can do (most egregious cases) according to the statues but what they will do according to their limited resources and policy. The probabilities of being "Zwernered" are very low.
 http://www.mnp.ca/en/media-centre/blog/2014/6/15/attention-americans-foreign-bank-accounts-reporting-fbar-online-filing-is-now-mandatory