How to File the FBAR: A Complete Guide for US Expats

If you’re an American living abroad, you may need to file a Foreign Bank Account Report (FBAR) each year, even if you don’t owe any US taxes. The FBAR helps the US government ensure compliance with foreign account reporting rules and prevent money laundering.

For many expats, understanding when and how to file can be confusing.

Don’t worry. In this guide, we’ll simplify the FBAR process, explain who needs to file, and help you meet your reporting requirements.

What’s a Foreign Bank Account Report (FBAR)?

The Foreign Bank Account Report (FBAR), officially FinCEN Form 114, is an annual reporting requirement under the Bank Secrecy Act of 1970. The US government combats tax evasion and financial crimes by requiring US persons to disclose foreign financial accounts that exceed certain value thresholds.

FBARs are filed electronically through the BSA E-Filing System and go to the Financial Crimes Enforcement Network (FinCEN), not the IRS. FinCEN is a bureau of the US Treasury that monitors financial activity to prevent money laundering and other illicit behavior.

FBAR Filing Requirements

You must file an FBAR if the combined maximum values of all your foreign financial accounts exceeded $10,000 at any point during the calendar year, even for a single day.

This applies to all US citizens, Green Card holders, and anyone who meets the IRS substantial presence test. It also includes US entities such as corporations, partnerships, or trusts with a financial interest in or signature authority over foreign financial accounts.

Real-Life Example 1

Claudia, a US expat living in Italy, keeps $6,500 in one Italian bank and $5,000 in another. Although neither account alone exceeds $10,000, their combined maximum balance does, meaning Claudia must file an FBAR for the year.

Real-Life Example 2 – Transferring the Same Money Between Accounts

Now, let’s say Claudia has two Italian bank accounts. Early in the year, she held $6,000 in Bank 1. Later, she transferred the same $6,000 to Bank 2, which then reached a peak balance of $6,000.

Even though Claudia never had more than $6,000 in total at one time, the combined maximum balance ($6,000 + $6,000 = $12,000) exceeds $10,000. Because the FBAR looks at each account’s highest balance at any point during the year, she must file an FBAR for that year.

Financial Interest vs. Signature Authority

• Financial interest means you own or control the funds in an account, even if it’s not in your name (for example, through a business partner or attorney).
• Signature authority means you can manage or direct transactions in an account without owning it, common for employees with access to company accounts or adult children assisting elderly parents.

Real-Life Example

David, a US expat living in Germany, has signature authority over his 12-year-old daughter’s savings account, which holds $8,000. He also maintains his own personal checking account in Germany, which has a balance of $4,000.

Even though he doesn’t own his daughter’s account, the combined total of all foreign accounts he can access is $12,000. Because this amount exceeds $10,000, David must file an FBAR for the year.

Currency Conversion

All balances must be reported in US dollars using the Treasury’s official year-end exchange rate. For consistency, use the same rate across all accounts. You can find the official rates on the Treasury Reporting Rates of Exchange.

Foreign Financial Accounts That Must Be Reported

Reportable Foreign bank and financial accounts include:

• Foreign bank and savings accounts
• Investment and brokerage accounts
• Pension and retirement plans
• Certain life insurance policies with cash value

Even if you didn’t earn any taxable income from these accounts, you still need to file if the total balance exceeded the threshold.

The FBAR Deadline

The FBAR is due April 15 each year, aligning with the standard US tax filing deadline.

However, if you miss that date, you automatically receive an extension until October 15, no separate form or request is required.

This automatic extension applies only to the FBAR, not your federal US tax return.

If you need more time to file your tax return, you must request it separately by filing Form 4868 before June 15, the automatic extension filing deadline for US expats.

Do Online Wallets Count as Foreign Financial Accounts?

It depends on where the account is opened and regulated.

Online wallets and payment platforms, such as Wise (formerly TransferWise), PayPal, or Revolut, can count as foreign financial accounts for FBAR reporting if the account was opened abroad or is held under foreign regulation.

For example, a PayPal account opened in Japan or a Wise account regulated in the UK would be considered foreign accounts because they fall under non-US financial regulation (such as the UK’s Financial Conduct Authority (FCA)

However, if your online wallet or account is held through a US-regulated bank or entity, even if the company operates internationally, it’s not considered a foreign account for FBAR purposes.

Adding Your Spouse or Children

Each US person with foreign financial accounts must file an FBAR if the combined balance exceeds $10,000 at any time during the year. This includes accounts owned by a spouse or dependent child.

If your child holds foreign accounts (such as a savings account or trust) exceeding the threshold, they must also have an FBAR filed on their behalf. Parents with signature authority over a child’s account must include that account’s maximum balance when filing their own FBAR.

If you and your spouse share only joint accounts, you can file a single FBAR as long as:

• All accounts are jointly owned, and
• Both spouses sign the FBAR using FinCEN’s required declaration.

If either spouse also holds individual accounts, each must file a separate FBAR.

How to File an FBAR

You can file the FBAR electronically by submitting FinCEN Form 114 through the BSA e-filing System.

The process is separate from your US tax return and goes directly to FinCEN (the Financial Crimes Enforcement Network), not the IRS.

Before you start, gather the following details for each foreign account:

• Maximum account balance for the year (converted to US dollars using the Treasury’s year-end exchange rate)
• Account number
• Financial institution name and address
• Type of account (e.g., savings, checking, investment)

Once submitted, you’ll receive confirmation through the BSA system.

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FBAR vs. FATCA: What’s the Difference?

It’s easy to confuse FBAR and FATCA since both involve reporting assets held outside the US. However, the FBAR focuses on foreign financial accounts, while the Foreign Account Tax Compliance Act (FATCA) covers a broader range of foreign financial assets.

Although some of the reporting overlaps, for example, both include foreign bank accounts, the thresholds and filing methods are different. Many US expats end up needing to file both each year.

Feature	FBAR (FinCEN Form 114)	FATCA (Form 8938)
Purpose	Reports foreign financial accounts held outside the US	Reports foreign financial assets, including ownership in companies, trusts, or partnerships
Who Has to File	US individuals and legal entities (citizens, residents, corporations, partnerships, trusts, or estates) with foreign accounts	US individuals only (citizens and resident aliens) who meet the asset thresholds
Threshold	Combined balance of $10,000 or more at any time during the year	Single expats abroad: $200,000 at year-end or $300,000 at any point (varies by filing status and residence)
What’s Reported	Foreign financial accounts — such as bank, brokerage, pension, mutual fund, and life insurance accounts held abroad	Foreign financial assets — including bank and investment accounts, business ownership, stock in foreign corporations, and interests in foreign partnerships or trusts
Where It’s Filed	Filed electronically through FinCEN, separate from your tax return	Filed on Form 8938 with your tax return as part of Form 1040 to the IRS
Due Date	April 15 (automatic extension to October 15)	June 15 for expats — same as your tax return; can extend to October 15 with Form 4868
Penalties for Non-Filing	Up to $10,000 per non-willful violation or 50% of account value for willful failure	Up to $10,000 per violation, with higher penalties for intentional non-reporting

FBAR Penalties for Non-Compliance

If the FBAR sounds optional, it’s not. The US government takes foreign account reporting seriously, and failing to file can lead to steep civil or even criminal penalties depending on your situation.

The IRS distinguishes between non-willful and willful violations, essentially, whether you made an honest mistake or knowingly failed to report.

Violation Type	Potential Penalty
Non-Willful	Up to $10,000 per violation (adjusted for inflation) if you unintentionally fail to file or report all accounts.
Willful	The greater of $100,000 or 50% of the account’s highest balance per year — and in some cases, potential criminal prosecution.

What Recent Cases Mean

Recent court rulings, including the Bittner v. United States Supreme Court decision, clarified that non-willful penalties apply per form, not per account. In that case, a $2.7 million penalty was reduced to about $50,000, a significant win for taxpayers who made honest mistakes.

Still, the safest route is timely and accurate filing. Even small oversights can add up quickly, and willful noncompliance can be financially devastating.

Delinquent FBAR Submission Procedures

If you’re otherwise current on your tax returns but have missed filing FBARs, you may qualify to file them late penalty-free under the Delinquent FBAR Submission Procedures.

This option applies if you:

• Have not been contacted by the IRS or FinCEN about the missing FBARs, and
• Properly reported and paid tax on all income from your foreign accounts.

Simply file the overdue FBARs with a short explanation stating why they were late

Streamlined Filing Procedures

For expats who missed both FBARs and US tax returns, the IRS offers an amnesty program called the Streamlined Filing Compliance Procedures. The program allows you to catch up and become compliant without penalties, as long as your failure to file was non-willful.

You can submit up to six years of FBARs and three years of past due tax returns while explaining that the oversight was unintentional.

Don’t Wait for the IRS to Contact You

If the IRS contacts you about unfiled FBARs first, you’re no longer eligible for penalty relief programs like the Streamlined Filing Compliance Procedures or the Delinquent FBAR Submission Program.

Once they’ve reached out, the case becomes an enforcement matter — meaning fines and even criminal penalties may apply.

Under FATCA, foreign financial institutions (FFIs) are required to report account details of US persons to local tax authorities, who share this information with the IRS. With these reporting agreements in place, it’s nearly impossible to hide unreported foreign accounts.

MyExpatTaxes Can Help

Filing your FBAR doesn’t have to be complicated, especially when it’s built right into your tax return. At MyExpatTaxes, our Full Base Plan automatically includes FBAR and FATCA reporting, so you can file everything together with no extra forms or surprise fees.

If you’ve unintentionally fallen behind, don’t worry. The IRS Streamlined Filing Procedures offer an official way for expats to get back on track safely and become compliant again penalty-free. We can guide you through the process step by step so you can get back on track confidently.

Sign up today and simplify your expat tax and FBAR filing, all in one place.

Frequently Asked Questions