FBAR For Crypto: When & How To Report
Do you need to file an FBAR for crypto? The guidance is often unclear, but in some instances, you may need to. Learn when and how to file a crypto FBAR.
U.S. persons must file an FBAR (FinCEN Form 114) if the total value of their foreign accounts exceeded $10,000 at any point during the year.
Crypto is not yet formally required on the FBAR, but if it is held in a foreign account with other reportable assets, the entire account must be reported. Many taxpayers choose to disclose foreign crypto accounts voluntarily.
The FBAR is due on April 15 each year, with an automatic extension to October 15. Penalties for not filing can be up to $10,000 for non-willful violations and over $100,000 for willful violations.
Foreign exchanges such as Binance.com, KuCoin, and Bitfinex may trigger FBAR reporting, while US-based platforms such as Coinbase, Kraken, and Gemini do not.
What is an FBAR?
The FBAR, formally known as FinCEN Form 114, was once called the Report of Foreign Bank and Financial Accounts.
Its purpose is to monitor overseas financial holdings and help deter illegal activities such as tax evasion. Any U.S. person who had $10,000 or more combined across foreign bank accounts at any point during the year must disclose those balances.
While the information reported can affect taxes, the form is not submitted to the IRS. Instead, it is filed electronically with the U.S. Treasury Department under the Bank Secrecy Act system.
Do I need to file an FBAR for crypto?
At present, FinCEN has not fully implemented cryptocurrency reporting on the FBAR. However, the agency announced in 2020 that digital assets would eventually be included. As of 2025, no formal rules have been finalized.
That said, if your crypto is held in a foreign account that also contains other reportable assets, such as cash or securities, and the combined balance exceeded $10,000 at any time during the year, you must report the entire account value. Many taxpayers also choose to voluntarily disclose foreign crypto accounts over $10,000 to stay ahead of evolving regulations and avoid penalties.
Read next: How to Report Crypto on Taxes
Who needs to file an FBAR?
The obligation to file isn’t limited to U.S. citizens. It applies to “U.S. persons,” which includes:
Citizens of the United States
Green card holders
Lawful permanent residents
Businesses incorporated in the U.S. (partnerships, corporations, LLCs)
Trusts with at least one U.S.-based trustee
If you meet this definition and hold qualifying foreign accounts whose total value exceeds $10,000 at any point during the year, you must file an FBAR. This traditionally covers bank accounts, retirement accounts, and securities accounts, but cryptocurrency accounts may soon be included once FinCEN issues final guidance.
What about joint ownership?
When a foreign account, crypto or otherwise, is jointly owned, each U.S. person listed on the account will generally be required to report it. If you hold both individual and joint accounts, you’ll likely need to disclose both once the total value of your foreign holdings surpasses $10,000.
Because the rules for digital assets are still evolving, and penalties for noncompliance can be significant, it’s wise to consult a tax professional if you have substantial crypto or other foreign assets.
When is the FBAR filing deadline?
The FBAR is due each year on the same date as your federal tax return, generally April 15, though this may be extended due to holidays or weekends. If you miss that date, you automatically receive an extension until October 15. No separate request is required to take advantage of this extension.
What are the penalties for not filing an FBAR?
At this time, there are no penalties specifically for failing to report cryptocurrency specifically on the FBAR, but that is expected to change as FinCEN finalizes its digital asset rules. For traditional accounts, however, the penalties are significant:
Non-willful violations: If you fail to file simply because you didn’t know about the requirement, the fine can be up to $10,000 for each violation.
Willful violations: If you intentionally avoid filing, the penalty can reach $100,000 per violation, and in some cases may be even higher depending on account value.
Read next: Crypto Taxes Guide
How to file an FBAR
Before filing, gather the following details for each foreign account:
The highest balance during the year (converted to U.S. dollars using the year-end exchange rate)
Account holder’s name
Account number or identifying code
Name and address of the bank, exchange, or institution holding the account
Although cryptocurrency accounts are not yet formally required, they are expected to be included in the future. Here’s a simple overview of how to file your FBAR through FinCEN’s online system:
Provide personal information: Start by entering your identifying details in the first section of the form.
Report account details: List your foreign accounts. Use Part II if filing as an individual or Part III for joint accounts.
Add multiple accounts if needed: If you have more than one account, click the “+” button in the form to include additional entries.
Review and submit: After confirming all account details are correct, sign electronically and submit the form.
What is Form 8938?
Form 8938 is part of the Foreign Account Tax Compliance Act (FATCA) requirements. Like the FBAR, it is designed to track foreign financial assets, but it is submitted to the IRS as part of your annual tax return, not to FinCEN.
The two forms serve overlapping purposes, but they are not interchangeable. You may be required to file both if you meet the thresholds. A key difference is that Form 8938 generally applies at higher reporting thresholds than the FBAR. The IRS offers a detailed comparison chart outlining the distinctions between the two forms.
Who must file Form 8938?
Whether you must file depends on your filing status and the value of your foreign assets:
Single filers: Required if total foreign assets exceed $50,000 on the last day of the year, or $75,000 at any time during the year.
Married filing separately: Same thresholds as single filers ($50,000/$75,000).
Married filing jointly: Required if combined foreign assets exceed $100,000 on the last day of the year, or $150,000 at any point during the year.
Importantly, filing Form 8938 does not replace the FBAR requirement. If you meet the conditions for both, you must complete each form separately.
Which crypto exchanges are foreign-based?
If you’re unsure whether the platforms you use are considered foreign, here’s a breakdown of some of the most common exchanges.
Popular foreign crypto exchanges
If your combined balances across foreign accounts exceed $10,000, you’ll generally need to include them on your FBAR. Examples of foreign-based platforms include:
Binance.com
KuCoin
Bitfinex
ByBit
Huobi
BitMEX
OKEx
CEX.io
Gate.io
MEXC
Popular U.S.-based exchange
Assets kept on U.S. exchanges do not need to be reported on an FBAR, since they are not considered foreign accounts. Examples include:
Binance.US
Cash App
Coinbase
Gemini
Kraken
Robinhood
Uphold
Read next: Best Crypto Exchanges
What about decentralized exchanges (DEXs)?
In most cases, transactions made through decentralized protocols such as Uniswap do not trigger FBAR reporting, provided both you and your wallet are US-based. However, this area remains gray, and future guidance may change the reporting rules.
How Koinly can help
Koinly can help with all your IRS and other reporting requirements. Simply import your data via API or by uploading a CSV file from more than 950 supported exchanges, and Koinly will generate a range of reports to help you file easily. Sign up for free.
