Accountant Cindy Laporta at Manafort's trial a bit ago:

[Kensan]

4. She was smart to negotiate for immunity...

The Circular 230 penalties the IRS could/would assess her in this matter were also going to be quite substantial. Not to mention, she could have been further reprimanded with loss of license or ability to practice before the IRS (which is a huge blow to a CPA).

The FBAR penalties are no joke. They are enforced in full, especially since it appears Manafort's banking activities in this trial began in years when the IRS was providing a Voluntary Disclosure program of foreign bank accounts. The whole point was to have people volunteer foreign banking information and report earned income, that most likely had never been taxed in the U.S., in exchange for a blanket waiver of the civil penalties. The taxpayer would still owe the interest and late payment penalties on any tax due. The program was extended, too, since it was working as intended to incentivize proper tax reporting compliance.

Manafort is really up a stinky creek without a paddle on this one. The paper trail of all the money transfers will sink him, and provide all the ammunition for tax evasion, in addition to the failure to report civil penalties. Couldn't happen to a nicer jerk.