FinCEN Form 114 – FBAR Reporting Explained

When working with FinCEN Form 114, the official filing known as the Foreign Bank Account Report (FBAR) that U.S. persons must submit each year to disclose foreign financial accounts. Also called FBAR, it is administered by the U.S. Treasury Department, the federal agency that oversees financial‑crime prevention and reviewed by the Internal Revenue Service (IRS), the tax authority that enforces filing penalties. The requirement falls under Anti‑Money‑Laundering (AML) regulations, rules designed to stop illicit money flow. Understanding FinCEN Form 114 helps you avoid costly fines and stay compliant.

FinCEN Form 114 encompasses the disclosure of any foreign bank account, brokerage, or crypto‑exchange holding that exceeds $10,000 in aggregate value at any time during the calendar year. That means if you own Bitcoin on a non‑U.S. platform, that balance counts toward the threshold. The form also captures traditional assets like foreign savings accounts, mutual funds, and even offshore trusts. By linking crypto holdings to the same filing, regulators can see the full picture of a taxpayer’s worldwide financial exposure.

How to File and What to Watch For

Filing is done electronically through the BSA E‑Filing System, a secure portal run by the Treasury. The deadline mirrors the IRS schedule—April 15, with an automatic extension to October 15 if you file a tax return on time. Missing the deadline triggers civil penalties that can reach up to $10,000 per violation, and willful non‑compliance can lead to criminal prosecution. Because the FBAR is separate from the IRS Form 8938 (the FATCA disclosure), you may need to file both if you have significant crypto assets.

Compliance steps are straightforward: first, identify every foreign account you held in the year, including wallets on exchanges that issue a statement of holdings. Next, gather account numbers, maximum balances, and the institution’s name and address. Finally, upload the data to the BSA portal, sign electronically, and keep a copy for at least five years. Keeping detailed records makes the filing process painless and protects you if the Treasury requests additional information.

Penalties can be steep: civil fines can reach up to $100,000 per non‑filing, and the Treasury can impose criminal charges that include imprisonment. The Financial Action Task Force (FATF) has also increased scrutiny on virtual‑asset service providers, meaning that crypto exchanges are now part of the AML ecosystem that feeds into FBAR data. Staying ahead of these rules not only saves money but also builds a compliance habit that benefits any future international financial activity.

Below you’ll find a curated collection of articles that walk through each step—from eligibility checks to filing tips and crypto‑specific guidance—so you can file confidently and stay on the right side of the law.