Late FATCA

First a reminder that a US person (someone who is a citizen, green card holder, or someone who is considered a resident for tax purposes) must file a US tax return and report all their world-wide income and pay tax on it.  Although your friend might not have been trading (no capital gains or losses) if she received interest or dividends, those were taxable in the US.  She may need to file amended returns to report that income.  If that income was also taxed in a foreign country, she can claim an offsetting deduction or credit, but she will still be required to file amended returns and report the income.

Then, any person who is a US person for tax purposes is required to report ownership of certain foreign assets, bank account and trading accounts. She may be required to file form 8938, an FBAR report, or both.  See these links.

https://www.irs.gov/businesses/corporations/fatca-information-for-individuals

https://www.irs.gov/businesses/comparison-of-form-8938-and-fbar-requirements

To file form 8938 for prior years, it would be attached to amended tax returns for those years. 

To file an FBAR for a prior year, use the regular online system.  Select the year you need to enter, and give a reason for the late form.  Here are some IRS comments.

Filing late FBARs

If a U.S. person learns that they should have filed an FBAR for a previous year, they should electronically file the late FBAR as soon as possible. The BSA E-Filing System allows them to enter the calendar year they’re reporting, including past years. It also offers them an option to explain the reason for the late filing or show if it’s part of an IRS compliance program.

https://www.irs.gov/newsroom/understand-how-to-report-foreign-bank-and-financial-accounts

Filing Delinquent FBARs

Filing an FBAR late or not at all is a violation and may subject you to penalties. If the IRS hasn’t contacted you about a late FBAR and you’re not under civil or criminal investigation by the IRS, you should file late FBARs as soon as possible to keep potential penalties to a minimum.

Follow these instructions to explain your reason for filing late. If you’re using a compliance option, such as  the Streamlined Filing Compliance Procedures, follow the instructions for the specific compliance option. 

https://www.irs.gov/businesses/small-businesses-self-employed/report-of-foreign-bank-and-financial-accounts-fbar