Without distracting from the question re. 2nd Pillar, I recommend US citizens who may not be fully aware of recent changes to take a look at the 2008 document
IR-2008-79, which outlines penalties that can result from not filing the FBAR. Quote: "
Civil penalties for a non-willful violation can range up to $10,000 per violation. Civil penalties for a willful violation can range up to the greater of $100,000 or 50 percent of the amount in the account at the time of the violation. Criminal penalties for violating the FBAR requirements while also violating certain other laws can range up to a $500,000 fine or 10 years imprisonment or both. Civil and criminal penalties may be imposed together."
The point that lacks clarity in the instructions, though, is whether 2nd Pillar retirement accounts fall under the reporting requirements or not. Any informed opinions on this?