Is there a statute of limitations on FBAR penalties?
Yes. The IRS has six years from the FBAR due date to assess civil FBAR penalties, and criminal FBAR charges carry the general five-year federal limitations period. The six-year civil clock runs whether or not you ever filed the FBAR.
The civil clock
Civil FBAR penalties must be assessed within six years of the violation, which is the filing due date for that year's FBAR. Unlike income tax, where an unfiled return leaves assessment open forever, the FBAR clock runs even if nothing was filed.
What this does not mean
Each annual FBAR violation has its own limitations period. An IRS civil examination or IRS Criminal Investigation makes a taxpayer ineligible for Streamlined, but does not eliminate the statutory reasonable-cause exception or make a penalty automatic. For 2026, the non-willful statutory maximum is $16,536 per annual report; a willful violation has a different statutory ceiling. These are exposure limits, not the cost of waiting or a predicted assessment.
Reference information, not legal or tax advice. Figures come from our verified fact base and are checked against superseded values on every site update.