What about Canadian banks?
I don't know for sure.
It is question of amounts. What is it worth for the Feds to pursue? Also, how "diversified" is the bank/geography? How easy is it for you to manage and what's your level of comfort with that bank/geography? For working stiffs like me with little net worth, having something off-shore that is easier to access and understandable (like Canada) might be good enough.