FBAR Explained: Foreign Bank Account Reporting for US Expats

FBAR is one of the most misunderstood — and most penalized — reporting requirements for US expats.

Many Americans abroad fail to file simply because they don’t realize it applies to them. Unfortunately, ignorance does not protect you from penalties.

This guide explains what FBAR is, who must file, and how to stay compliant.

What Is FBAR?

FBAR stands for Foreign Bank Account Report.

It is filed using FinCEN Form 114 and reports certain foreign financial accounts held outside the United States.

FBAR is not a tax form, but it is legally required.

Who Must File FBAR?

You must file an FBAR if:

• You are a US citizen or green card holder, and

• The total value of all foreign accounts exceeds $10,000 at any point during the year

This includes temporary spikes — even for one day.

What Accounts Are Reportable?

Common reportable accounts include:

• Foreign checking and savings accounts

• Joint accounts

• Foreign investment accounts

• Some pension and retirement accounts

Even accounts you don’t actively use may still count.

FBAR vs FATCA (Form 8938)

Many expats confuse FBAR with FATCA.

Key differences:

• FBAR is filed with FinCEN

• FATCA is filed with your tax return

• Thresholds and rules differ

Some expats must file both.

FBAR Deadlines

FBAR deadlines:

• April 15 (automatic extension to October 15)

• No separate extension request needed

Missing the deadline can result in penalties even if no tax is owed.

FBAR Penalties

Penalties can be severe:

• Non-willful violations: up to $10,000 per violation

• Willful violations: significantly higher

This is why proactive compliance is critical.

Missed FBAR Filings: What to Do

If you missed FBAR filings in previous years:

• Do not ignore it

• Do not file randomly without a plan

The IRS offers programs that may allow you to catch up without penalties if mistakes were non-willful.

Staying Compliant Going Forward

FBAR compliance becomes manageable when:

• Accounts are tracked properly

• Reporting thresholds are understood

• Filings are reviewed annually

If you’re unsure whether your accounts are reportable or whether you’ve missed filings, Exemplary can help you assess your risk and guide you through the safest next steps.