FBAR Direct prepares and files your FBAR (FinCEN Form 114) for you. You must review all data for accuracy before we send it to FinCEN. This article is for info only and is not tax, legal, or financial advice.

What Counts as Foreign Financial Account FBAR? The Definitive List

If you must file FBAR the FBAR rules require you to know which accounts on your list actually count. The Report of Foreign Bank and Financial Accounts — FinCEN Form 114 — requires every US person to report foreign accounts when the aggregate value of those accounts exceeds at any time $10,000 during the calendar year. But what is a "foreign financial account" under federal law? The definition is broader than most filers expect.

This guide covers every type of account the FBAR rules include. It also covers every type they exclude, plus the gray areas that trip up even experienced tax professionals. The Report of Foreign Bank and Financial Accounts FBAR rules apply to bank accounts, brokerage accounts, retirement accounts, insurance policies with cash value, or other financial arrangements abroad. You will find a clear answer below. If you are new to the FBAR, start with our first-time filer guide.

What Counts as Foreign Financial Account FBAR Rules?

The legal basis comes from 31 CFR 1010.100(t). An account is any banking or financial link set up for regular services. A foreign account is one held at a bank or firm outside the US.

Under 31 CFR 1010.350(c), a US person must file FBAR if that person has a financial interest in foreign account holdings or signature authority over accounts in foreign country jurisdictions. The rule applies when account values exceed $10,000 at any time during the calendar year. Whether an account is "foreign" depends on one factor: where the bank sits. The currency, the holder's citizenship, and the source of funds do not matter.

31 USC 5314 grants the Secretary of the Treasury authority to require reports of foreign financial accounts. The Financial Crimes Enforcement Network (FinCEN) administers the act and runs the FBAR on behalf of the Treasury Department.

The FBAR is a Bank Secrecy Act filing. The BSA filing system accepts the form electronically through the BSA E-Filing System. The due date for the FBAR is April 15, with an automatic extension to October 15. Penalties may apply for violations. Non-willful penalties reach $16,117 per violation, and criminal penalties can apply in willful cases. Who must file? Generally, any US person is required to file an FBAR if the aggregate value of foreign accounts tops $10,000 at any time during the reporting year. This includes individuals and entities such as corporations partnerships limited liability companies and trusts. Check for additional filing requirements in addition to the FBAR for federal tax purposes. Taxpayers should also check Form 114a authorization and report all owned accounts.

Which Bank Accounts Count as Foreign Financial Accounts for FBAR?

Among all accounts the most common on FBARs are deposit accounts at a foreign bank. You must report every bank account at a financial institution outside the United States. The foreign accounts include checking, savings, and fixed deposits.

Account Type	Reportable?	Notes
Foreign checking account	Yes	Any deposit account at a foreign bank
Foreign savings account	Yes	Including high-yield or tiered accounts
Certificates of deposit (CDs)	Yes	Fixed deposits, time deposits
Money market accounts	Yes	Deposit accounts at a foreign bank
Foreign currency accounts	Yes	Currency type does not matter
Prepaid debit card accounts	Yes	If issued by a foreign financial institution
Dormant or inactive accounts	Yes	Zero-balance accounts still count if open

To determine whether an account counts as a foreign financial account for FBAR, follow these steps:

Check if the financial institution sits outside the United States
Confirm that you hold a financial interest in or signature authority over the account
Add the account's maximum value to your aggregate total across all foreign accounts
File an FBAR if the aggregate exceeds $10,000 at any point during the year

You must report the maximum value of the account during the calendar year for each account. Convert values to US dollars using the Treasury exchange rate. See how to calculate maximum account value for FBAR.

Even an account you have not used in years counts if it stays open. The account must be reported on the FBAR during the year if open, even if dormant. List the following information for each account on FinCEN Form 114: account number, institution name, and the maximum value. All accounts maintained at foreign financial institutions go on the FBAR. In reasonable cases where you cannot find the exact maximum value, use the best information available.

Do Brokerage Accounts, Stocks, and Bonds Count for FBAR?

Foreign brokerage accounts are foreign financial accounts under the FBAR rules. If you hold stocks, bonds, or other securities through an account in a foreign country, you must report that account on the FBAR. You need to file an FBAR to report the account if its value, combined with your other foreign accounts, tops $10,000.

Account Type	Reportable?	Notes
Foreign brokerage accounts	Yes	Stocks, bonds, options, derivatives
Demat accounts (India)	Yes	Dematerialized securities accounts
Foreign margin accounts	Yes	Accounts held at foreign brokerages
US-listed stocks held at a foreign broker	Yes	Location of the broker determines status

Specifically, you report the account — not each security. If you hold Apple stock through a broker in London, that account is foreign. What matters is whether the financial institution that holds the account is in a foreign country. For all such accounts the FBAR filing rules apply. These accounts sit with foreign brokers and go on the FBAR the same way as bank accounts.

Are Mutual Funds and ETFs at Foreign Financial Institutions Reportable?

If you hold mutual funds or exchange-traded funds (ETFs) through a foreign financial institution, the account counts as foreign. Under 31 CFR 1010.350(c)(3), an account with a mutual fund or other pooled fund qualifies if the fund sits in a foreign country.

Account Type	Reportable?	Notes
Foreign mutual fund accounts	Yes	Any pooled fund at a foreign institution
Foreign unit trusts	Yes	Common in the UK, Australia, and India
Foreign ETFs held in foreign accounts	Yes	Account location decides
US mutual funds held at a US broker	No	Domestic account, not reportable

Furthermore, mutual fund accounts opened abroad stay reportable on the FBAR for as long as the account exists — even for years after you stop adding money. It does not matter whether you still receive income from it. Accounts to report include any pooled fund in foreign financial institutions. File by the deadline each year to avoid penalties.

Do Insurance Policies With Cash Value Count for FBAR?

Yes — insurance policies with a cash surrender value count as foreign financial accounts when a foreign entity issues them. Under 31 CFR 1010.350(c)(3), the FBAR covers any policy with a cash value held at a person or entity in a foreign country.

Account Type	Reportable?	Notes
Foreign whole life insurance	Yes	Cash value makes it a financial account
Foreign endowment policies	Yes	Common in the UK and India
Foreign annuity contracts	Yes	Annuities with a surrender value
Foreign term life insurance	No	No cash value — not a financial account
Domestic US insurance policies	No	Not foreign

Ask one question: does the policy have a cash value or surrender value? If it does, and the issuing entity sits in a foreign country, you must report it on the FBAR. You must report insurance policies with cash value on the form. They count toward your aggregate total. Whole life and endowment policies with cash value go on the FBAR the same way as bank accounts. Don't overlook policies with cash value held by a spouse — both spouses must file as required. The FBAR or Form 8938 may both apply, so check FBAR requirements and FATCA rules. Term life insurance has no cash value and is not a financial account. For more on this topic, see FBAR foreign life insurance policies.

Are Pensions and Retirement Accounts Reportable on the FBAR?

Foreign pension and retirement accounts rank among the most missed items on FBARs. Importantly, tax-free or tax-deferred status in a foreign country does not exempt an account from FBAR reporting. If you have financial interest in or signature authority over a foreign retirement account, you must report it. Accounts in foreign countries — even those with foreign tax benefits — still go on the FBAR when the aggregate exceeds the $10,000 threshold.

Account Type	Reportable?	Notes
Foreign employer pension plans	Yes	Even if you cannot access funds yet
UK SIPPs and ISAs	Yes	UK tax benefits do not apply to FBAR
Canadian RRSPs and TFSAs	Yes	Treaty may help on income tax, not FBAR
Australian superannuation	Yes	Qualifies as a financial account
Indian PPF, NPS, EPF accounts	Yes	Government-managed accounts still count
Israeli pension funds	Yes	See Israel guide
US 401(k) or IRA	No	Domestic retirement plans are not reportable

The IRS takes the position that foreign retirement accounts must be reported on the FBAR. A tax treaty between the US and a foreign country may cut your federal income tax on retirement income. But it does not end your FinCEN reporting duty. The FBAR is a BSA filing run by the Financial Crimes Enforcement Network — not a tax return filed with the IRS. Once filed the report goes to FinCEN. See FBAR foreign pension and retirement accounts.

Does Cryptocurrency on Foreign Exchanges Count for FBAR?

FinCEN has signaled that crypto accounts at foreign exchanges will count for FBAR reporting. As of 2026, no final rule exists. But proposed rules under 31 CFR 1010.350(f)(2) would add accounts with foreign entities holding virtual currency to the FBAR list.

Account Type	Reportable?	Notes
Crypto account at a foreign exchange (e.g., Binance)	Check current rules	Proposed rule would require FBAR reporting
Self-custody wallet (hardware/software)	No	No financial institution holds the account
Crypto held at a US exchange (e.g., Coinbase)	No	Domestic institution

Until the final rule takes effect, filers should watch FinCEN guidance. Most tax professionals recommend conservative reporting. If you hold cryptocurrency at a foreign exchange and the account has real value, consider filing the FBAR for it. The account if held with a foreign entity may need to go on your FBAR. See FBAR cryptocurrency and foreign exchanges for current rules and proposed changes.

Do Trusts and Other Financial Arrangements Trigger FBAR?

Trusts and other financial arrangements that hold foreign accounts can trigger FBAR filing. If a US person has financial interest in or signature authority over a foreign account held by a trust, that account goes on the FBAR. Under 31 CFR 1010.350(e), a US person has financial interest when the owner or beneficiary holds more than 50% of the account value or trust assets.

Account Type	Reportable?	Notes
Foreign trust bank account (you are trustee)	Yes	Signature authority over the account
Foreign trust (you are beneficiary >50%)	Yes	Financial interest in the account
Foreign trust (you are beneficiary <50%)	Depends	May still have reporting duties
Accounts held by a foreign entity you own	Yes	If you own >50% of the entity

As a result, trust reporting on the FBAR is fact-specific. A US person who serves as trustee has signature authority over the trust's foreign accounts. That triggers FBAR filing. A beneficiary may have financial interest based on ownership share and trust terms. Report each account with the trust's account details. See FBAR trust reporting requirements.

What Does NOT Count as a Foreign Financial Account for FBAR?

Not every foreign asset counts as a foreign financial account. However, people often confuse the FBAR with Form 8938. The FBAR only covers the accounts that FinCEN defines as financial. Below are items filers wrongly believe they must report.

Item	Reportable on FBAR?	Why Not
Foreign real estate	No	Real property is not a financial account
Foreign art, jewelry, collectibles	No	Physical assets, not accounts
Correspondent/nostro bank accounts	No	Exempt under [31 CFR 1010.350(c)(4)]
US branch of a foreign bank	No	Treated as a domestic institution per FinCEN
Foreign stock held directly (not in an account)	No	Bearer certificates are not an account
Social Security benefits from a foreign government	No	Government payments are not an account

Foreign Real Estate

In contrast, owning a home abroad does not create an FBAR filing duty. Real estate is not a financial account. But money in a foreign bank account to pay for the property counts. Rental income in a foreign account also makes that account reportable.

US Branches of Foreign Banks

Similarly, an account at a US branch of a foreign bank — for example, HSBC in New York — is not foreign for FBAR. The institution holds the account in the US. The same applies to US subsidiaries of foreign banks.

Correspondent and Nostro Accounts

Banks use correspondent and nostro accounts for global transactions. Under 31 CFR 1010.350(c)(4), these interbank accounts do not go on the FBAR.

Are PayPal, Digital Wallets, and Precious Metals Reportable?

PayPal, digital wallets, and precious metals in foreign vaults fall into gray zones for FBAR reporting. Whether an account counts as foreign depends on which entity holds the account and where that entity sits.

Account Type	Reportable?	Analysis
PayPal held by a foreign subsidiary	Possibly	Depends on which entity maintains the account
Foreign digital wallet (Revolut UK, Wise)	Yes	Foreign financial institution holds it
Precious metals in a foreign depository	Possibly	If held in an account at a foreign institution
Foreign prepaid cards	Yes	If the card issuer is a foreign financial institution
Offshore gaming or betting accounts	Yes	If held at a foreign entity with financial services

For example, PayPal accounts create confusion. A PayPal account with PayPal Inc. (US entity) is not foreign. But a PayPal account run by PayPal Europe (Luxembourg) sits with a foreign financial institution and must go on the FBAR. Check your statements to learn which entity holds your account.

Precious metals in a foreign vault may count. Gold in a custodial account at a foreign bank — where the bank tracks your holdings — counts as reportable. Renting a safe deposit box to store metals yourself is typically not a financial account under 31 CFR 1010.100(t).

How Do Financial Interest and Signature Authority Trigger FBAR?

Financial interest and signature authority are the two ways to trigger an FBAR filing. You must file an FBAR if you have financial interest in or signature authority over a foreign financial account per 31 CFR 1010.350(e).

Financial interest means you are the owner of record or holder of legal title to the account. It also applies if someone holds it for your benefit, or you own more than 50% of an entity that owns the account. The owner of record or holder of legal title has a financial interest. Anyone with an interest in a foreign account must report it.

Signature authority means you can control money or other authority over assets in the account. The authority over an account includes the power to direct transfers of money. A corporate officer who signs checks on a business's foreign bank account has signature authority — even without a personal financial interest. The account if under your control triggers an FBAR.

As a result, both triggers require FBAR reporting. When you file your FBAR the form must list all accounts if you meet the threshold. The time for filing is due by April 15. See FBAR $10,000 threshold and aggregate value.

How Does FBAR vs. Form 8938 (FATCA) Define Foreign Accounts?

The FBAR and Form 8938 both cover foreign financial accounts, but they define "specified foreign financial assets" differently. The form is filed with FinCEN for the FBAR, while Form 8938 goes on your federal tax return under 26 USC 6038D. Form 8938 covers a broader set of foreign financial assets including foreign stock held directly and foreign partnership interests. The Internal Revenue Service enforces Form 8938 penalties. Within the IRS the audit division handles enforcement. FinCEN handles the FBAR form and its filing.

Feature	FBAR (FinCEN Form 114)	Form 8938 (FATCA)
Filed with	FinCEN (BSA E-Filing System)	IRS (with your tax return)
Threshold	$10,000 aggregate	$50,000–$200,000 (varies)
Covers foreign accounts	Yes	Yes
Covers foreign stock held directly	No	Yes
Penalties	Civil and criminal per 31 USC 5321	Civil penalties under IRC 6038D
Due date	April 15 (auto-ext Oct 15)	Filed with tax return

You may need to file both forms. Individuals, spouses filing jointly, and resident aliens should check both sets of requirements. Anyone may be required to file both forms if the value exceeds at any time the relevant threshold. Understanding the scope of FBAR when compared to Form 8938 helps you stay compliant. Form 8938 attaches to your federal income tax return, while the FBAR goes to FinCEN. See FBAR vs. FATCA Form 8938 differences.

Key Takeaways

The following list covers the most important points about what counts as a foreign financial account for FBAR reporting. These key takeaways help you decide which accounts go on your FBAR and which do not. Use this list as a quick reference when checking your foreign accounts against FinCEN rules.

A foreign financial account is any account at a financial institution in a foreign country — bank accounts, brokerage accounts, mutual funds, insurance policies with cash value, and retirement accounts all qualify
The location of the institution decides whether an account is foreign — not the currency or the account holder's citizenship
Foreign real estate is not a financial account and does not go on the FBAR
US branches of foreign banks count as domestic — those accounts are not foreign
The FBAR must be filed by the deadline of April 15 (auto-extended to October 15) when you have financial interest in or signature authority over foreign accounts and the aggregate value tops $10,000 at any time of the calendar year
Criminal and civil penalties for failure to file reach $16,117 per penalty (non-willful) or 50% of the account balance (willful) under 31 USC 5321
A spouse who owns foreign accounts must also file a separate FBAR or be reported on a joint filing

Frequently Asked Questions

The most frequently asked questions about what counts as a foreign financial account for FBAR cover real estate, pensions, cryptocurrency, precious metals, and signature authority. Each answer reflects current FinCEN guidance and IRS positions as of 2026.

Does foreign real estate count as a foreign financial account for FBAR?

No. Foreign real estate is not a financial account under 31 CFR 1010.100(t). But if you hold money in a foreign bank account tied to that property — such as a mortgage escrow account or a rental income account — that bank account goes on the FBAR.

Do I need to report a foreign retirement account on the FBAR?

Yes. Foreign retirement accounts — including pensions, superannuation, RRSPs, SIPPs, PPF, and NPS accounts — count as foreign financial accounts. Tax treaty benefits that cut your federal income tax do not end FBAR reporting. See FBAR foreign pension and retirement accounts.

Is an account at a US branch of a foreign bank reportable?

No. An account at a US branch of a foreign bank counts as a domestic account for FBAR purposes. The account sits in the US, not in a foreign country. An account at the same bank's branch in London would count as foreign.

Does cryptocurrency on a foreign exchange count for FBAR?

FinCEN has proposed rules that would require FBAR reporting for virtual currency accounts at foreign exchanges. As of early 2026, the final rule has not come out. Most tax professionals recommend conservative reporting. See FBAR cryptocurrency and foreign exchanges.

What if I have signature authority over a company's foreign account but no ownership?

You must still file the FBAR. Signature authority over a foreign financial account triggers the filing requirement even without financial interest or ownership in the account. Under 31 CFR 1010.350(f), a person with signature authority over one or more foreign accounts must report those accounts if the aggregate value tops $10,000.

Do I report a foreign account with a zero balance?

Yes. An open account at a foreign financial institution goes on the FBAR even if the balance is zero. The account adds $0 to the aggregate total. But if your other foreign accounts push the total above $10,000, you must include the zero-balance account on your FBAR.

Are precious metals in a foreign vault reportable on the FBAR?

It depends on the setup. If your gold or silver sits in a custodial account at a foreign financial institution — where the institution keeps account records and tracks your holdings — that account counts as reportable. If you rent a safe deposit box and store physical metals yourself, that is typically not a financial account under 31 CFR 1010.100(t).

What is the difference between FBAR reporting and Form 8938?

Filers submit the FBAR to FinCEN through the BSA E-Filing System. It covers foreign financial accounts with a $10,000 aggregate threshold. Form 8938 goes on your federal income tax return to the IRS. It covers a broader set of specified foreign financial assets starting at $50,000. You may need to file both. See FBAR vs. FATCA Form 8938 differences.

Let FBAR Direct Handle Your Filing

For all accounts the FBAR covers, figuring out which count is the first step. You still need to gather statements, convert values to US dollars using the Treasury rate, and complete FinCEN Form 114. Most filers find it easier to let a professional handle their FBARs.

Let FBAR Direct prepare your filing — upload your foreign account statements and we handle conversion, form preparation, and filing to FinCEN on your behalf. You review and approve before we submit. See how it works.

Tax regulations change frequently. Always verify current requirements at IRS.gov or FinCEN.gov. Once filed your FBAR stays on record with FinCEN. For advice specific to your situation, consult a qualified tax professional. This article is current as of April 3, 2026.