Latest Facts & News

• The 2025 FBAR deadline remains April 15, 2025, with an automatic extension to October 15, 2025.
• The $10,000 threshold for the unchanged combined value of all foreign accounts triggers the filing requirement.
• Electronic filing is mandatory through the BSA E-Filing system; no paper submissions are accepted.
• IRS increased enforcement with over 800,000 FBAR filings processed annually.

Foreign account reporting never starts with a form. It starts with small details, balances that cross a limit, shared accounts that aren’t fully understood, or signatory rights that seem minor. For many, the FBAR filing requirements appear not as a clear rule but as a vague obligation that’s easy to miss until it becomes a problem. 

In 2025, that hasn’t changed. The filing rules remain the same, but enforcement continues to grow. To understand how these rules apply, it’s essential to first identify the specific criteria and how common accounts may be subject to them.

Read along to see how FBAR filing requirements apply in different situations and what needs to be reported before the deadline arrives.

What Are FBAR Filing Requirements?

If you are a U.S. person, and you have money outside the United States, you might have to file an FBAR.

Who Is Required to File FBAR: Complete Eligibility Guide

You must file an FBAR if all these are true:

• You are a U.S. person. This means you are a U.S. citizen, green card holder, resident, or a business registered in the U.S.
• You have one or more foreign bank or financial accounts.
• At any time in the year, all your foreign accounts together had more than $10,000 in value, even if it was just for one day.

Important Points to Remember →

• The $10,000 threshold is the combined total value of all your foreign accounts, not just one.
• You need to include accounts that you have a financial interest in. This means:
  • You fully own the account.
  • You share ownership with someone else, or
  • You have the right to benefit from the money in the account, even if it’s not in your name.
• You also need to include accounts where you have signature authority. This means:
  • You do not own the money, but
  • You have the power to control or direct how the money is used by signing for the account.
• Many types of accounts count: checking, savings, brokerage, retirement, or pension accounts held outside the United States.

If all of these apply, you must file your FBAR every year. If not, you do not have to file.

Understanding the Bank Secrecy Act Foundation

After learning who must file the Foreign Bank Account Report (FBAR) and why, it helps to know where this rule comes from and why it matters for everyone in the U.S.

The Bank Secrecy Act is the law behind the FBAR. The U.S. government created this law to find and stop money crimes like hiding money, not paying taxes, or moving illegal money using foreign bank accounts.

Here are the key points about this law:

• The Bank Secrecy Act says that people in the U.S. who have certain accounts outside the country must inform the government.  Basically, if you have money in foreign banks, you need to report it.
• The job of collecting and protecting this information belongs to a government group called the Financial Crimes Enforcement Network (FinCEN). They handle all the paperwork and data.
• This law is important because, before it existed, some people moved money to bank accounts in other countries to hide it from taxes or from the law. People were using offshore accounts to avoid paying what they owed.

Note: Now, with the Bank Secrecy Act and the FBAR form, the government can see if people are being honest about their money, even if the money is kept in another country.

When you file your FBAR, you are following this law. You are showing that your accounts follow the rules, and you are helping make the financial system safer and fairer for everyone. This is why the FBAR is not just extra paperwork; it is a way to protect people, stop illegal actions, and make sure there is honesty about money, both inside and outside the U.S.

FBAR vs. Tax Return Filing

FBAR and your tax return are not the same thing. They are two separate forms that go to different places.

• The FBAR is a report you send to the FinCEN. You use the FBAR to tell the government about your bank and financial accounts outside the United States. You file it only if you meet the FBAR filing requirements.
• Your tax return is a form you send to the Internal Revenue Service (IRS). On your tax return, you report your income, claim deductions, and figure out how much tax you owe or refund you get. Almost everyone files a tax return each year.

You might be wondering how these two separate filings actually connect. Many people ask questions like

Do I send the FBAR with my tax return?

No. You do not send the FBAR together with your tax return. You file your tax return with the IRS, but you file the FBAR separately, online, with FinCEN.

Do I pay anything when filing the FBAR?

No. Filing the FBAR is free. It is just a report, not a tax.

Why do I have to file both?

The government uses your tax return to check your income and taxes. The FBAR helps the government know about money and accounts you have in other countries. Reporting both helps show you are following all the rules.

FBAR Reporting Requirements: What Accounts Must Be Reported

If you need to file the FBAR, you must list all accounts outside the United States that the rules cover. Below is a clear guide, with every detail you need, nothing more, nothing less.

Reportable Foreign Financial Accounts

You must report every bank or financial account outside the United States if the FBAR rules apply to you, as part of the FBAR reporting requirement. This includes:

• Checking accounts
• Savings accounts
• Bank deposit accounts of any kind
• Investment or brokerage accounts
• Mutual fund accounts
• Pension or retirement accounts from foreign jobs
• Foreign life insurance or annuity policies with cash value
• Accounts in foreign credit unions or cooperative banks

If you have the money, share the account, or can sign for it, you must put it on your FBAR.

Examples from Other Countries

Some common foreign accounts people in the U.S. may have include:

• In Canada: RRSP (Retirement Savings Plan), TFSA, RESP
• In the United Kingdom: ISA (Individual Savings Account), premium bonds, foreign work pensions
• In Australia: Superannuation accounts
• In India: NRE and NRO accounts, foreign mutual funds

If you have an account in another country, and it is a bank, investment, or financial account, you may need to report it. If you are ever unsure, it is safest to include it.

Accounts Exempt from FBAR Reporting

• Accounts you hold in banks or financial institutions inside the United States. If it’s a US bank, you don’t need to worry about it.
• Accounts owned by a government, federal, or state agency in the U.S. government are already covered.
• Accounts at U.S. military banks, even if they are outside the U.S. military banking system, don’t count, even overseas.
• Certain retirement and pension plans are already reported by your U.S. employer. Your work probably handles this stuff already.
• Certain accounts held by an international organization or a U.S. government agency.

Some special cases with international groups. You also do not report Social Security or U.S. government benefit payments. Government benefits do not require reporting.

Note: These exemptions are very specific. If your account does not fit one of these categories, you should plan to include it in your FBAR.

Joint Accounts and Special Situations

Joint, shared, or special accounts need careful reporting:

• If you share a foreign account with someone else (like your spouse or a business partner), you must report the full value of the account.
• If your spouse does not file their own FBAR, you may be able to include their accounts on yours, but you both must sign a special statement.
• If you are named on a foreign account for an elderly parent, a child, or a business, and you can sign or direct money, you must include it—even if you do not use the money.
• Trusts and certain business accounts count if you can control or benefit from them.

If you have accounts with people who are not U.S. persons, you still have to report your share or any account you can sign for.

FBAR Filing Process: Step-by-Step Guide to FinCEN Form 114

Step 1: Gather All Account Information 

Before you start, collect the details for every foreign bank or financial account you need to report. You will need:

• Name and address of the bank or financial institution: Just write down where the bank is located.
• Account number: The number they gave you when you opened the account.
• Highest balance in the account during the year (in the account’s currency): Whatever was the most money you had in there at any point.
• Type of account (checking, savings, investment, etc.): Just say what kind of account it is.
• Your full name, address, and Social Security Number or ITIN: Your basic personal information.

Make sure you have all this to accurately fill out the form. Don’t want to mess up because you forgot something. 

Step 2: Convert Foreign Currency Balances to U.S. Dollars 

Each account balance must be converted to U.S. dollars using the official exchange rate set by the U.S. Treasury for December 31 of the reported year.

• Use the highest balance of the year in foreign currency. Take the biggest amount you found.
• Multiply by the Treasury exchange rate for that day. They tell you what rate to use.

Note: If no official rate exists, use an IRS-approved rate. There are backup options if needed. This way, you can see if your combined accounts exceed the $10,000 threshold. This helps you figure out if you even need to file. 

Step 3: Access and Use the BSA E-Filing System

• Visit the official BSA E-Filing website to file the FBAR online. The government has its own website for this.
• If this is your first time and you file as an individual, you can file without creating an account. makes it easier for new people.
• Follow the instructions on the website to complete FinCEN Form 114. They walk you through it. 

Step 4: Fill Out the Form Carefully

• Enter all required information for each foreign account you report. Put in everything they ask for.
• Double-check all information for correctness before you submit. Mistakes can cause problems later. 

Step 5: Submit the FBAR and Save Confirmation

• Submit your FBAR electronically through the BSA E-Filing system. Everything is done online now.
• After submission, save or print your confirmation page and filing reference number for future records. Keep this stuff safe in case you need it.

FBAR Deadlines and Extensions for 2025

The FBAR for the 2024 calendar year is due on April 15, 2025. If you do not file by this date, you automatically have until October 15, 2025, to file. 

The extension is automatic; you do not need to apply or fill out any extra forms, which means you get more time without having to ask for it.

Key points to remember →

• If April 15 or October 15 falls on a weekend or holiday, the deadline moves to the next business day. makes sense because government offices are closed on weekends.
• This deadline applies to all U.S. persons, including people living outside the U.S. Be sure to check your local time zone to avoid missing the deadline. Even if you live in another country, you still have to follow these dates.
• The FBAR deadline and extension are separate from any extension you may have for your tax return. This has nothing to do with your regular tax filing extensions.
• If you file after October 15 and do not have a good reason, you may have to pay penalties. The government will fine you if you miss the deadline without a valid excuse.

FBAR Penalties and Consequences of Non-Compliance

If you fail to file your FBAR or report incorrectly, the government may penalize you. 

Non-Willful FBAR Penalties

For non-willful mistakes, the penalty can be up to $10,000 per year, no matter how many accounts you missed. The IRS may lower or remove this penalty if you show reasonable cause, such as an honest error or something you could not control.

Willful FBAR Penalties and Criminal Consequences

If you knowingly do not file or try to hide accounts, the willful penalty is much higher. It can be the greater of $100,000 or 50% of the account balance for each violation. You may also face criminal charges and possible jail time if your actions are found to be willful.

FBAR Penalty Mitigation and Appeals

You can ask for penalty relief if you had a reasonable cause for not filing. You can also appeal FBAR penalties with the IRS. If you need to challenge an FBAR penalty, getting help from an experienced attorney like Antony N. Verni can make the process easier and improve your chances of reducing or eliminating FBAR penalties.

FBAR vs. FATCA: Understanding the Differences 

You may need to file two forms if you have foreign assets: FBAR and FATCA. Basically, there are two different reporting requirements here:

• FBAR means reporting foreign bank accounts using FinCEN Form 114. So this is basically for your bank accounts in other countries.
• FATCA means reporting other foreign financial assets using IRS Form 8938. And this one is for other financial stuff you might have overseas.

These rules cover different assets, so you might need to file both. The thing is, you have to understand which one applies to what you have.

Common FBAR Filing Mistakes and How to Avoid Them

Many people make errors when filing FBAR. These mistakes can cause penalties, delays, or extra IRS review. Knowing common errors helps you avoid problems.

• Mistakes include not combining the value of all foreign accounts to check the $10,000 filing threshold. 
• Some miss dormant or little-used accounts, which still must be reported. Incorrect bank names, addresses, or account numbers cause filing errors.
• Others omit accounts like mutual funds, pensions, or insurance policies that meet the rules. 
• Some file late or miss deadlines, risking penalties. Not reporting accounts you control or can sign for is another frequent error.
• Confusing FBAR with tax return reporting is also common. FBAR must be filed separately from your tax return.

Get Expert Help When You Need It Most!

Given all of that complexity regarding FBAR filing, sometimes the weight of so many regulations, forms, deadlines, and convoluted procedures gets to every U.S. taxpayer having foreign accounts. There is no slight mistake when a simple step or detail is missed: penalties could ensue, or, at worst, jail time.

When you are not sure about filing an FBAR or if a challenge arises, you should go to someone who is well familiar with the process, a professional with deep knowledge of the subject. That is Anthony N. Verni. He has been around helping a lot of taxpayers for various years to comply with FBAR filing requirements and can now reliably guide you away from costly errors and legal complications.

If you need answers, feel stuck, or just want to be sure that your FBAR is being done right, give us a call or book a consultation with us.

FAQS

Do I need to file an FBAR if my foreign account balance was only $9,000?

No. You must file an FBAR only if the total value of all your foreign accounts exceeded $10,000 at any time during the year.

What happens if I discover unreported foreign accounts from previous years?

You should report those accounts as soon as possible. The IRS provides programs to file late or update past reports, which can lower penalties.

Can I file an FBAR if I don’t have a Social Security Number?

Yes. You can file an FBAR without a Social Security Number by using an IRS Individual Taxpayer Identification Number (ITIN) or following special FinCEN rules.

Is there a statute of limitations for FBAR penalties?

No. FBAR penalties have no statute of limitations. This means the government can charge penalties for missed filings from any year.

Do cryptocurrency accounts held on foreign exchanges require FBAR reporting?

Yes. If you control or have financial interest in cryptocurrency accounts on foreign exchanges, and the total value of your other foreign accounts exceeds $10,000, you must report them on FBAR.