I’m sure he knew what he was doing. Foreign income is a biggie with the IRS. in 2013 they started cracking down on it hard.
FATCA was the revenue-raising portion of the 2010 domestic jobs stimulus bill at the time US didn't realize all the problems could be solved by printing money. The U.S. has yet to comply with FATCA itself, because as of 2017, it has not yet provided the promised reciprocity to its partner countries and it has failed to sign up to the Common Reporting Standard (CRS).
FATCA only generated about 250 million revenue each year since its implementation but caused lots of pains for everyone involved as the law applies retroactively.