As a reminder, U.S. citizens, resident aliens and any domestic legal entity with foreign financial accounts must file their annual Report of Foreign Bank and Financial Accounts (FBAR) with Financial Crimes Enforcement Network (FinCEN) by April 15, 2025. Individuals who fail to file by the deadline are automatically extended to Oct. 15. 

Who Must File?

The Bank Secrecy Act (BSA) mandates U.S. individuals to file FBARs under the following circumstances:

• An individual has a financial interest in, signature authority or other authority over one or multiple accounts (bank accounts, mutual funds or other financial accounts located outside of the United States) and
• The total value of all foreign financial accounts is greater than $10,000 at any point during the calendar year.

Given these requirements, U.S. individuals or entities with foreign accounts, no matter the size, are recommended to see if they qualify for FBAR filing requirements to avoid possible penalties. Note, individuals who report all foreign financial accounts on a consolidated FBAR or jointly own all their foreign financial accounts with their spouse and have completed and signed FinCEN Form 114a are not required to file for the calendar year. 

Keeping Records

Generally, individuals required to file must keep these records for five years from the due date of the FBAR. For each account you must report on an FBAR, you must keep records with this information: 

• Name on the account
• Account number
• Name and address of the foreign bank
• Type of account
• Maximum value during the year

The law doesn’t specify the type of document to keep with this information. Documents may include bank statements or a copy of a filed FBAR if they have the required information. 

How to File

The FBAR must be filed electronically with FinCEN, not on a federal income tax return. It can only be accessed and submitted through the BSA E-Filing System. Anyone unable to e-file their FBAR within the United States must contact FinCEN. 

File Today to Avoid Penalties

Anyone who fails to file their FBAR when required could fall victim to substantial civil and criminal penalties that could result in a fine and/or prison time. If you need assistance filing your FBAR before the deadline, Doeren Mayhew’s international tax advisors stand ready to help.