Zerohedge offers US expats a new strategy for filing:
Just remember, the US courts have decided on the basis of the Required Records Doctrine that you can’t plead the 5th Amendment with regard to the FBAR. Of course, FATCA obliterates your 4th Amendment and Canadian Charter Rights as well. Could this be hypocrisy?
IRS Email Hunt Shows Lerner Switched To Texts, Which Aren’t Kept….’Perfect’
And keep in mind that under Treasury regulations for the Bank Secrecy Act, shredding a bank statement from four years and eleven months ago is a crime just like failing to file an FBAR:
http://www.law.cornell.edu/cfr/text/31/1010.420