Millions of U.S. citizens, green card holders, and residents living in the United States 🇺🇸 or abroad face a firm annual duty this filing season: the FBAR, or FinCEN Form 114. The Financial Crimes Enforcement Network (FinCEN), a bureau of the Treasury, requires an annual report from any U.S. person who had foreign financial accounts totaling more than $10,000 at any time during the calendar year.
For 2025 filings covering 2024 accounts, the FBAR is due by April 15, with an automatic extension to October 15. No extra form is needed to get this six-month extension, FinCEN confirms.
The rule is simple on paper but often missed in practice, especially by immigrants and dual nationals who keep savings or retirement funds in another country. The FBAR is filed electronically with FinCEN, not with an IRS tax return, and it’s separate from any income tax filing. FinCEN says the requirement applies to both a direct “financial interest” and “signature authority,” meaning people who can control an account—even if it’s not theirs—may need to file.
Who must file and what counts as a foreign account
FinCEN’s rule covers a broad range of filers. A “U.S. person” includes:
– U.S. citizens
– Lawful permanent residents (green card holders)
– Individuals who meet the substantial presence test
– Entities formed in the United States
If the combined value of all foreign accounts topped $10,000 even for one day, the FBAR must be filed.
Reportable foreign financial accounts include:
– Checking and savings accounts at non-U.S. banks
– Brokerage and investment accounts
– Retirement accounts and mutual funds held abroad
– Life insurance policies with cash value
– Trusts and similar financial vehicles
Certain accounts are exempt, such as those owned by governmental entities or international financial institutions, U.S. military banking facilities, IRAs, and some trust accounts. Filers should review exemptions carefully, especially when accounts are held through employers or family trusts abroad.
Timing, extensions, and special cases for 2025
- The FBAR deadline is April 15 every year, with an automatic extension to October 15.
- For the 2025 season, FinCEN reiterates that no separate extension request is required.
- People with only signature authority and no financial interest benefit from a different extended deadline for 2025 filings: their FBARs are due April 15, 2026.
- Married couples can file a joint FBAR when all foreign accounts are jointly owned, but they must complete and retain the authorization
FinCEN Form 114ato do so. (The authorization is kept in records and not submitted with the FBAR.)
According to analysis by VisaVerge.com, many filers miss the April deadline because they assume FBAR is part of a federal tax return or they don’t realize small, scattered balances across several accounts can still cross the $10,000 threshold. Even a brief spike due to a deposit or currency change can trigger the filing requirement.
FinCEN requires all amounts to be converted to U.S. dollars using the Treasury’s official exchange rate for the last day the account held a balance during the year. Records supporting each figure must be kept for at least five years. That includes:
– Account numbers
– Names and addresses of foreign institutions
– Maximum balances
– Ownership details
Penalties and documentation
For 2025, the penalties for non-compliance remain steep:
– Non-willful violations: up to $16,536 per violation
– Willful violations: the greater of $165,353 or 50% of the account balance at the time of violation
FinCEN stresses that people should not guess on balances. Careful year-end statements, bank letters, or online screenshots can help document maximum balances in each account.
Filing is done only through FinCEN’s BSA E-Filing System. The report is the electronic FinCEN Form 114, which captures each foreign account’s details and the highest balance during the year. The joint-filing authorization FinCEN Form 114a must be signed and kept in the filer’s records but is not submitted with the FBAR.
The FBAR is not a tax, but a reporting requirement designed to protect the financial system and support law enforcement.
FinCEN maintains a dedicated page with official guidance on who must file, how to report accounts, and how to address common errors.
Who is most affected
This rule affects many communities with deep ties abroad:
– New green card holders who keep a savings account in their home country while settling in the U.S.
– International students who later change status and meet residency rules while holding small brokerage accounts overseas
– U.S. professionals with global careers who retain retirement accounts in another country after moving back home
In each case, the same trigger applies: if the total value of all foreign accounts crossed $10,000 at any point in the year, an FBAR is required.
Common pitfalls
- Believing a low average balance avoids filing when a one-day spike crossed the threshold
- Reporting to the IRS but forgetting the separate FinCEN report
- Missing accounts where you have signing power, such as a family member’s account you can access
- Ignoring foreign life insurance with cash value or pooled investment funds
- Using the wrong exchange rate or not keeping clear records for five years
Practical steps to stay compliant
- Make a list of all non-U.S. accounts at the start of the year and update it monthly.
- Track highest balances, not just year-end balances.
- Confirm whether you have signature authority on any account, including at work or in family settings.
- Save statements, screenshots, and exchange rate references in one folder.
- Calendar the April 15 due date and note the automatic extension to October 15.
For expatriates, dual citizens, and global families, compliance can feel like one more task during tax season. But the process is straightforward once accounts are identified and documents are in order. Early preparation reduces the risk of mistakes and avoids last-minute scrambling in October.
Filing, corrections, and professional help
FinCEN encourages electronic filing as the fastest and most reliable method. If corrections are needed, amended filings can address errors, but it’s better to get the first filing right.
People with complex account structures, pooled funds, or business accounts should consider professional advice—especially when foreign account reporting intersects with foreign income tax reporting.
Officials emphasize that the FBAR requirement protects the integrity of the system and helps deter financial crime. At the same time, the broad reach of the rule means everyday filers—immigrants, retirees, and families—must plan ahead each year. With the April 15 deadline and automatic extension, filers have a clear timetable to meet the obligation and avoid penalties.
Useful official resources
- FinCEN’s FBAR overview and guidance: Report Foreign Bank and Financial Accounts (FBAR)
- File the electronic FBAR:
FinCEN Form 114via BSA E-Filing - Joint filing authorization:
FinCEN Form 114a(Authorization to file FBAR)
This Article in a Nutshell
FinCEN requires U.S. persons — including citizens, green card holders, residents meeting the substantial presence test, and U.S. entities — to file an FBAR (FinCEN Form 114) if the combined value of foreign financial accounts exceeded $10,000 at any time during the calendar year. For 2025 filings covering 2024, the deadline is April 15 with an automatic extension to October 15; no separate extension request is necessary. The FBAR covers direct financial interest and signature authority and includes checking, brokerage, retirement accounts, and life insurance with cash value. Filers must convert foreign amounts to U.S. dollars using the Treasury exchange rate for the last day the account held a balance and retain supporting records for five years. Penalties are substantial: up to $16,536 per violation for non-willful breaches and the greater of $165,353 or 50% of the account balance for willful violations. Filing is electronic via FinCEN’s BSA E-Filing System, and married couples may file jointly if they retain a signed FinCEN Form 114a authorization in their records. Filers should inventory accounts, track maximum balances, confirm signature authority, and preserve documentation to avoid mistakes.
