2026-02-21

How to File FBAR as an Expat (Step by Step)

If you are a US citizen or green card holder living abroad with foreign financial accounts, you are almost certainly required to file FBAR — the Report of Foreign Bank and Financial Accounts. Failing to file can result in penalties starting at $10,000 per violation, and willful non-compliance can lead to criminal prosecution. This guide walks through the entire process step by step, from determining whether you need to file to submitting the form through FinCEN’s BSA E-Filing system.

What Is FBAR?¶

FBAR stands for Foreign Bank Account Report, though the form itself is officially called FinCEN Form 114 — Report of Foreign Bank and Financial Accounts. It is administered by the Financial Crimes Enforcement Network (FinCEN), a bureau of the US Department of the Treasury, not the IRS. However, the IRS has been delegated enforcement authority.

The legal basis for FBAR is the Bank Secrecy Act (BSA), 31 U.S.C. Section 5314, and its implementing regulations at 31 CFR 1010.350. According to FinCEN, any US person who has a financial interest in or signature authority over foreign financial accounts must file FBAR if the aggregate value of those accounts exceeds $10,000 at any time during the calendar year.

Who Must File?¶

You must file FBAR if you meet all three conditions:

1. You are a “United States person.” This includes US citizens (regardless of where they live), US residents (green card holders), and US entities (corporations, partnerships, trusts, LLCs).

2. You have a financial interest in, signature authority over, or other authority over one or more foreign financial accounts. “Financial interest” means you are the owner of record or the account is held by an entity in which you own more than 50%. “Signature authority” means you can control the disposition of assets in the account, even if you do not own it.

3. The aggregate value of all foreign financial accounts exceeded $10,000 at any time during the calendar year. This is not $10,000 per account. It is the combined total of all foreign accounts on any single day. If you have three accounts that individually never exceed $10,000 but together reach $10,001 on one day, you must file.

What Counts as a “Foreign Financial Account”?¶

According to FinCEN’s guidance, foreign financial accounts include:

• Bank accounts (checking, savings, time deposits)
• Securities accounts (brokerage accounts held at foreign financial institutions)
• Commodity futures or options accounts
• Insurance policies with a cash value (e.g., whole life insurance)
• Mutual funds or pooled investment funds
• Any other account maintained with a foreign financial institution

What does NOT count:

• Accounts held at US branches of foreign banks (these are considered US accounts)
• Real estate held directly (not through a foreign entity)
• Cryptocurrency held in personal wallets (not on a foreign exchange) — though this is an evolving area and the FinCEN has proposed rules to include certain digital assets

The $10,000 Threshold in Practice¶

The aggregate threshold catches more people than you might expect. If you are an expat living in the United Kingdom with a current account, a savings account, and an ISA at UK banks, plus a brokerage account at Interactive Brokers UK, the combined balances of all four accounts on any day of the year determine your filing obligation.

Here is a concrete example:

Even though no single account exceeded $10,000, the aggregate did, so FBAR filing is required.

Use the exchange rate on the day the aggregate balance was highest. FinCEN accepts the Treasury’s Financial Management Service rates for the last day of the calendar year, but you may also use reasonable commercial rates.

FBAR vs. FATCA Form 8938¶

FBAR is often confused with FATCA (Foreign Account Tax Compliance Act) Form 8938, Statement of Specified Foreign Financial Assets, which is filed with your tax return. They are separate requirements with different thresholds, different filing locations, and different penalties. You may need to file both.

The IRS publishes these penalty amounts in Revenue Procedure 2025-13 (adjusted annually for inflation). The FinCEN penalty amounts are similarly adjusted under 31 CFR 1010.821.

Deadlines¶

The FBAR filing deadline is April 15 following the calendar year being reported. So for the 2025 tax year, the FBAR is due April 15, 2026.

If you miss the April 15 deadline, there is an automatic extension to October 15. You do not need to file for this extension — it is granted automatically per FinCEN’s filing guidance. There is no penalty for using the automatic extension.

There is no further extension beyond October 15. If you miss both deadlines, you should file as soon as possible. Late filing without reasonable cause can trigger penalties, but filing late is better than not filing at all.

Step-by-Step Filing Instructions¶

Step 1: Gather Your Account Information¶

For each foreign financial account, collect:

• Name of the financial institution
• Account number
• Type of account (bank, securities, other)
• Maximum value of the account during the calendar year (in the account’s currency)
• Currency of the account
• Address of the financial institution

If you have accounts at multiple institutions across multiple countries — for example, a bank account in Portugal, a brokerage in Singapore, and a savings account in Germany — you need the details for every single one.

Step 2: Convert Maximum Values to USD¶

All values on the FBAR must be reported in US dollars. Convert each account’s maximum value using the Treasury Department’s end-of-year exchange rate, available on the Treasury Reporting Rates of Exchange page.

If you use FlashFi to track your investments across multiple currencies, you already have historical FX rates and account values readily available — which makes pulling together FBAR data significantly faster.

Step 3: Access the BSA E-Filing System¶

FBAR must be filed electronically through FinCEN’s BSA E-Filing system at https://bsaefiling.fincen.treas.gov. Paper filing is not accepted for individual filers.

You have two options:

1. Online form: Fill out FinCEN Form 114 directly in the browser. No account required. This is the simplest option for most people.
2. Batch filing: Upload an XML file. This is used by tax preparers filing on behalf of multiple clients.

To use the online form, go to the BSA E-Filing site and select “File FBAR” or navigate to the FinCEN Report 114 form.

Step 4: Fill Out the Form¶

The form has several sections:

Filer Information (Part I): - Your name, date of birth, Social Security Number (or ITIN) - Your current address (your foreign address is fine) - Filing type: select “Individual” for personal filing - Calendar year being reported

Account Information (Part II — repeat for each account): - Financial institution name and address - Account number - Type of account - Maximum account value during the year (in USD) - Whether you have a financial interest or signature/other authority - Whether the account was opened or closed during the year

Joint accounts: If you have a joint account with your spouse, both of you may be required to file. One spouse can file and the other can check the “spouse of filer” box, provided the joint account information is included on the first spouse’s filing. According to IRS guidance on FBAR, a spouse who does not have any other foreign accounts beyond the jointly held ones may use this method.

Step 5: Submit and Save Your Confirmation¶

After completing the form, review all entries carefully. Submit the form electronically. You will receive a confirmation page with a BSA Identifier (a tracking number). Save this confirmation. You should also save or print a copy of the completed form for your records.

FinCEN recommends keeping FBAR records for at least 5 years from the due date of the report.

Step 6: Keep Records for Future Filings¶

For each subsequent year, you will need to file again if you continue to meet the threshold. Maintain a record of:

• All foreign financial accounts you hold
• Monthly or quarterly balances (to determine the maximum value)
• Account opening and closing dates
• The financial institution details

Penalties for Non-Filing¶

FBAR penalties are severe, which is why this filing should not be treated casually.

Non-Willful Violations¶

If you failed to file but did not do so knowingly, the maximum penalty is $16,117 per violation (2025 amount, adjusted annually for inflation). “Per violation” generally means per account per year, though the IRS has discretion. In United States v. Bittner (2023), the Supreme Court clarified that non-willful penalties apply per form (per year), not per account — a significant reduction in potential exposure.

Willful Violations¶

If the IRS determines that your failure to file was willful — meaning you knew about the requirement and chose not to comply — the penalty is the greater of $161,175 or 50% of the account balance at the time of the violation. Willful violations can also result in criminal prosecution under 31 U.S.C. Section 5322, with penalties of up to $250,000 in fines and 5 years imprisonment.

Delinquent Filing Without Penalties¶

If you have not been contacted by the IRS about your failure to file, you may be eligible for FinCEN’s Delinquent FBAR Submission Procedures. Under these procedures, you can file late FBARs without incurring penalties, provided:

• The IRS has not already contacted you about the unfiled FBARs
• You are not under civil or criminal investigation
• You have not previously been assessed FBAR penalties

If your situation is more complex — for example, you have unreported foreign income — you may need to use the IRS Streamlined Filing Compliance Procedures or consult a tax professional.

Special Cases for Expats¶

Accounts in Countries Without Tax Treaties¶

If you hold accounts in countries that do not have a tax treaty or FATCA intergovernmental agreement with the US, the accounts still must be reported on your FBAR. The filing obligation is based on the US person’s status, not on the country where the account is held.

US Expats with PFICs¶

If your foreign brokerage account holds non-US mutual funds or ETFs, those may be classified as Passive Foreign Investment Companies (PFICs) under US tax law. PFICs have punitive tax treatment and separate reporting requirements (IRS Form 8621). See our guide to investing as a US expat with PFIC rules for details.

Crypto on Foreign Exchanges¶

If you hold cryptocurrency on a foreign exchange (e.g., an exchange incorporated outside the US), the question of whether this triggers FBAR is still evolving. FinCEN published a Notice of Proposed Rulemaking (NPRM) in 2020 that would require reporting of certain accounts holding digital assets, but as of early 2026, no final rule has been issued. Conservative practice is to include them, and several tax professionals recommend doing so.

How FlashFi Helps with FBAR Preparation¶

While FlashFi does not file your FBAR for you, it solves one of the most time-consuming parts of the process: knowing exactly what you hold, where, and what it was worth.

If you are tracking your foreign brokerage accounts, bank accounts, and savings accounts in FlashFi, you already have:

• A consolidated view of all your accounts and their values
• Historical balances converted to your home currency (and to USD)
• The ability to see your aggregate foreign account value at any point in time

For expats in the United States or US citizens living in countries like Thailand, Mexico, Colombia, or Portugal, this means less scrambling at tax time. You can review your account values in FlashFi, pull the maximum balances, and fill out your FBAR with confidence.

For more on building and tracking a multi-currency portfolio, see our guide on how to calculate net worth across countries.

Start tracking your global accounts with FlashFi — so FBAR season is not a scramble.

By David Brougham