Foreign bank account (FBAR compliance)

The FBAR is a mandatory annual filing for US persons with foreign financial accounts exceeding $10,000 in aggregate at any time during the year. Filed electronically on FinCEN Form 114 through the BSA E-Filing System.

11 steps across 2 sections

1. Steps Process

  • Determine filing requirement — File if you are a US person AND aggregate value of ALL foreign accounts exceeded $10,000 at any time.
  • Identify reportable accounts — Bank, brokerage, mutual fund, and other financial accounts at foreign institutions.
  • Determine maximum account values — Find max value during year. Convert to USD using Treasury year-end rate.
  • File FinCEN Form 114 electronically — File at bsaefiling.fincen.gov.
  • Meet the deadline — April 15 with automatic extension to October 15.
  • Maintain records — Keep records for 5 years from filing due date.

2. Key Details

  • Threshold: $10,000 aggregate (ALL foreign accounts combined)
  • Non-willful penalties: Up to $16,536 per violation (2025)
  • Willful penalties: Greater of $165,353 or 50% of account balance
  • FBAR is separate from FATCA Form 8938
  • Foreign retirement accounts and life insurance with cash value may be reportable

Common Mistakes

  • Not filing due to ignorance
  • Not including signature authority accounts
  • Using year-end balance instead of maximum value
  • Confusing FBAR with FATCA Form 8938

Pro Tips

  • Use Streamlined Filing Procedures to catch up without penalties if non-willful
  • Cryptocurrency on foreign exchanges may be reportable

Sources

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