What matters for reporting is U.S. citizenship, which triggers a report, or U.S. tax resident, which means either being a resident of the U.S. according to our general definition of the term or being a U.S. taxpayer by virtue of another heading, which would be citizenship. Whether dual or non-dual, if they are a U.S. citizen, they're potentially subject to reporting.
On May 29th, 2014. See this statement in context.