The US is cracking down on people of US nationality, even when they have less information because they live outside the US and make human mistakes. Read IRS Handed Another Defeat, Only For It To Retaliate. The article starts with:

Earlier this year, the IRS was handed yet another defeat in front of the Supreme Court, which found that its interpretation of statute governing reporting of foreign financial accounts was wrong. The IRS is handling its latest judicial rebuke in the worst way possible — with a sucker punch to taxpayers who make honest mistakes.