Do you have clients who have lived overseas? What about clients who were born in another country, and are now U.S. citizens or residents? If so chances are they have investments in overseas financial accounts which should have been reported, but weren't. Those who failed to file an FBAR Form TD F90-22.1. are subject to criminal penalties of up to five years in jail, a fine of $250,000 or both. Even if no criminal penalties are imposed there is still the matter of civil penalties which can equal 3 times the balance in the accounts!