FileVault doesn't seem to be secure at all if someone is willing to erase or reformat the volume and then run a recovery app.
Anyone serious about accessing your data would surely try this, once they were unable to provide the FV password.
I've been thinking of using FV on several external drives as well as my internal.
A few hours ago I took an external drive that had previously been wiped and erased it in Disk Utility.
I encrypted it in Finder and entered a password.
I ejected and unplugged the drive, then re-mounted it.
I entered my password to unlock it.
Then I copied a 280 GB video to it.
I ejected and re-mounted the volume, ignoring the password request.
In DU I erased the drive.
I ran two recovery apps for about 15 minutes each, both quickly found the video, and one was able to play it back perfectly while still scanning for deleted files. The other can't preview recovered files larger than 20 MB, so I stopped it. But the file size was correct, so I'm sure the entire video was recovered.
Maybe FileVault should be called FailVault.
OS X 10.11.3