Based on the following criteria, it would appear you may be in the clear when submitting your delinquent FBAR's. That is assuming you report the income and (whether or not) any tax was due on your tax returns(s) and/or amended tax return(s). If in doubt, check with your tax professional.
See: https://www.irs.gov/individuals/international-taxpayers/delinquent-fbar-submission-procedures
"Follow these steps to resolve delinquent FBARS
•Review the instructions
•Include a statement explaining why you are filing the FBARs late
•File all FBARs electronically at FinCEN
•On the cover page of the electronic form, select a reason for filing late
•If you are unable to file electronically, contact FinCEN's Regulatory Help line at 1-800-949-2732 or 1-703-905-3975 (if calling from outside the United States) to determine possible alternatives to electronic filing.
The IRS will not impose a penalty for the failure to file the delinquent FBARs if you properly reported on your U.S. tax returns, and paid all tax on, the income from the foreign financial accounts reported on the delinquent FBARs, and you have not previously been contacted regarding an income tax examination or a request for delinquent returns for the years for which the delinquent FBARs are submitted."
