This case is primarily about US citizens living in another country (and in this case, with dual nationality), having multiple local bank accounts, and not reporting them.

Accounts are easy to create. Eg, https://www.usbank.com/financialiq/manage-your-household/per... describes using multiple savings accounts to help with budget organization.

According to the linked-to piece, each of these needs to be reported, and each are subject to the maximum penalty, even though they are really just different buckets in the same bank.