Fincen Form 114
Updated on December 10, 2025
by Jeff Patterson
Jeff Patterson is an American living in Scotland and joined the team at Expat Tax Online after experiencing the complexities of living abroad with a family.
Table of Contents
Fincen Form 114: What it is for US expats
If you’re an American living abroad, FinCEN Form 114, also known as the FBAR, is probably one of those forms you’ve heard about but never fully unpacked. Here’s one easy rule to follow: If your foreign bank accounts ever topped US$10,000 in total at any point in 2025, you probably need to file an FBAR.
What is FinCEN Form 114 (FBAR)?
FinCEN Form 114 is the online report that US expats use to declare foreign bank and financial accounts when the total value exceeds US$10,000. It’s not a tax form.
FinCEN Form 114 is governed by the Bank Secrecy Act, not the IRS. You file it electronically through FinCEN’s BSA E-Filing system, not with your tax return. No paper forms. No attaching it to your 1040. Completely separate lane.
The purpose isn’t to tax your foreign money; it’s simply about transparency. The US wants a record of where Americans keep funds abroad. You may roll your eyes at that, but ignoring the FBAR can trigger penalties much larger than most people expect.
Who must file an FBAR in 2025?
Even if you’re abroad and haven’t lived in the US in years, you may still be a “US person” for FBAR purposes. Here’s who falls into that category.
Who counts as a US person?
A US person includes:
- US citizens (even if you haven’t lived in the States for years)
- Green Card holders
- US residents for tax purposes
- US entities such as LLCs, corporations, partnerships, trusts, and estates
Which foreign accounts does FinCEN Form 114 cover?
Foreign financial accounts can include:
- Bank accounts (current/checking/savings)
- Foreign brokerage accounts
- Joint accounts
- Foreign pension accounts (superannuation, PFIC-holding plans, retirement schemes)
- Certain annuity or insurance policies with cash value
- Investment accounts or managed portfolios
- Online/digital-only foreign financial platforms
Basically, if it’s a financial account at an institution located outside the US and it’s tied to you, it’s probably reportable.
What doesn’t need to be reported?
Some accounts fall outside FBAR rules:
- Foreign government accounts
- Correspondent/Nostro accounts
- Certain US-based retirement accounts with foreign exposures
- Accounts already fully reported by another US person, such as a US trustee or corporate filer, where you’re covered by their FBAR reporting
- Accounts you only access for your employer in an official capacity
Need to file your FBARs?
We’re here to help.
What is the US$10,000 FBAR threshold?
If the highest combined value of all your foreign accounts was over US$10,000 at any time in 2025, you must file FinCEN Form 114.
It doesn’t matter if:
- The money sat there for just one day
- The account earned zero interest
- One account has US$9,999 and another has US$2
It’s the aggregate value that triggers the requirement.
How do you calculate the “aggregate total”?
A quick breakdown:
- Find the highest balance of each account during the year.
- Convert each one to USD using the Treasury year-end exchange rate.
- Add them up.
- If the total exceeds US$10,000, you must file an FBAR.
Quick illustrations:
- One account example: You had €9,500 in a savings account. USD conversion pushes it slightly over US$10,000 → FBAR required.
- Multiple small accounts: A checking account with US$4,100 and a savings account with US$6,200, for a total of US$10,300 → FBAR required.
- Joint account with a spouse: If the account balance is US$12,000, you must report it, even if your spouse is not a US citizen.
- Foreign employer payroll accounts: If you have signing authority over a foreign payroll or company account—even if the company owns the money—that signature authority alone can trigger FBAR filing.
When is the FBAR due for the 2025 reporting year?
The FBAR deadline does not exactly follow the regular tax return deadline. It works like this:
FBAR deadlines for 2025 accounts
|
FBAR filing item |
Date |
Notes |
|
Original FBAR deadline |
April 15, 2026 |
Covers accounts for the 2025 calendar year |
|
Automatic extension |
October 15, 2026 |
No form needed, everyone gets it automatically |
|
Disaster-area extensions |
Varies |
Only if the IRS/FinCEN declares relief |
|
Holiday/weekend shifts |
Yes |
Moves to the next business day |
|
Signature authority extensions |
Varies |
FinCEN may publish notices that grant extra deadline relief |
Most US expats end up filing by October 15 because of the automatic extension, which takes a lot of timing pressure off.
How do you file FinCEN Form 114? (step-by-step guide)
Step 1: Gather your account details
You’ll need:
- Account numbers
- Bank or institution names
- Bank addresses
- Maximum yearly values
- Currency conversions using Treasury rates
The trickiest part is usually finding the highest balance for each account, but you can often work this out from your monthly or quarterly bank statements.
Step 2: File electronically through the BSA E-Filing System
You complete FinCEN Form 114 online through the BSA E-Filing portal.
There’s no mailing address. Do not attach it to your tax return. Everything happens electronically.
Step 3: If someone else files for you (like your tax preparer)
You’ll need to sign FinCEN Form 114a, which is just an authorization form.
You don’t submit it to FinCEN; it’s kept for your records and your preparer’s records.
A lot of expats choose this route because it keeps the process tidy, and FBAR mistakes tend to snowball if you’re guessing your way through.
What are the 2025 FBAR penalties?
The penalties for not filing an FBAR can be significant, and they increase every year due to inflation.
FBAR penalty table (2025 accounts)
|
Type of violation |
Maximum penalty (2025) |
Notes |
|
Non-willful |
Up to US$16,536 per report for non-willful violations |
Can apply even when the failure to file was an honest mistake |
|
Willful |
Greater of US$165,353 or 50% of the account balance |
Per violation, can stack per year |
|
Criminal penalties |
Fines + possible imprisonment |
Reserved for extreme, intentional cases |
FBAR vs. Form 8938: What’s the difference?
FinCEN Form 114 (FBAR) reports foreign bank accounts.
Form 8938 (FATCA form) reports foreign financial assets as part of your tax return.
People mix these up constantly, and honestly, it’s understandable. Both forms involve foreign assets, and the acronyms aren’t exactly friendly.
FBAR vs. Form 8938 (2025 accounts)
|
Feature |
FBAR (FinCEN Form 114) |
Form 8938 (FATCA) |
|
Filed with |
FinCEN (BSA E-Filing) |
IRS (attached to tax return) |
|
Threshold |
> US$10,000 aggregate |
Varies by filing status & residency |
|
Covers |
Bank accounts |
Broader financial assets |
|
Penalties |
Up to 50% of the account or inflation-adjusted |
IRS-based penalties |
|
Who files |
US persons |
Specific taxpayers meeting thresholds |
Do I need to file an FBAR if I live abroad?
Yes, probably. Living abroad actually increases your odds of needing to file because you’re more likely to use foreign banking systems.
Here are situations where expats almost always need to file:
- You’re paid into a foreign bank account.
- You keep savings overseas to avoid the US banking hassles.
- You have a foreign pension or retirement plan.
- You share a joint account with a spouse who isn’t American.
- You opened a local investment account “just to try it.”
- You left an old account open, even if it’s inactive.
Common FBAR filing mistakes to avoid
The most frequent mistakes include:
- Thinking Form 8938 replaces the FBAR
- Forgetting old accounts with low balances
- Not converting currencies correctly
- Reporting only the year-end value instead of the maximum value
- Missing joint accounts
- Forgetting to file Form 114a when a preparer files for you
Most of these are easy to fix when caught early, which is why filing each year helps you keep things tidy.
FAQs
-
What if I closed my foreign accounts before the end of 2025?
You still report them. The FBAR looks at any account you owned or controlled during the year, whether or not it still exists when you file. Closed accounts must be listed with their maximum value.
-
Do kids need to file FinCEN Form 114?
-
What if I discover past years I forgot to file?
-
I already pay tax abroad, does that exempt me from FBAR?
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