The Secretary of the Treasury and the IRS require United States citizens to report any relations with foreign banks to the U.S. government through a Report of Foreign Bank and Financial Accounts Form, or FBAR. 31 U.S.C. § 5314, 31 C.F.R. § 1010.350. The maximum penalty for a willful violation of this reporting requirement is either $100,000 or 50% of the balance of each bank account at the time of the violation, whichever is the greater amount. 31 U.S.C. § 5321(a)(5)(C)(i), (D)(ii).