FinCEN Form 114: Banking Overseas for US Persons

FinCEN Form 114 is an annual requirement for any US person with reportable foreign financial accounts.

So, if youโ€™re a US person with overseas accounts (or thinking about opening them) keep reading to determine if your accounts are (or will be) reportable.

This article is part of our free series on foreign bank accounts for US citizens, which covers reporting requirements for individuals, financial institutions, and more.

Feel free to use the table of contents to jump ahead to the sections most relevant to you.

Table of Contents

  1. FinCEN Form 114
  2. Who Needs to File a FinCEN Form 114?
  3. Frequently Asked Questions
  4. Do You Want Help Opening Bank Accounts?

FinCEN Form 114

FinCEN Form 114 is the form that US persons use to file a Report of Foreign Bank and Financial Accounts (FBAR) to the US government. Reporting qualifying foreign accounts is required compliance for all US persons each year.ย 

Form 114 is submitted to the US Treasury Department via the Financial Crimes Enforcement Network (FinCEN) using the online BSA E-Filing System.

The FinCEN Form 114 reporting requirement exists to help the US government ensure tax compliance, promote asset disclosure, combat money laundering, and help generate additional revenue through taxation.

The penalty for not filing an FBAR when you have reportable accounts is steep. So, it should not be tested.

Needless to say, FinCEN Form 114 is not the only anti-money laundering (AML) and tax related tool at the disposal of the US government. Financial regulations like FATCA are used to promote disclosure on the side of financial institutions, ensuring that the financial accounts of all US persons are reported.

Who Needs to File a FinCEN Form 114?

FinCEN Form 114 needs to be filed by any US person with reportable foreign financial accounts. Importantly, in order for a US person’s foreign financial account to be reportable, they must exceed an aggregate value of USD 10,000 at any point during the financial year.

In other words, if during the last tax year you had three overseas bank accounts with an aggregate value of USD 5,000 for 364 of the 365 days of the year, and on the very last day the aggregate value of these three accounts exceeds USD $10,000, your foreign financial accounts are now reportable.

Report Foreign Bank and Financial Accounts (FBAR)

To report your foreign financial accounts, you will need to submit an FBAR to the Treasury Department using FinCEN Form 114. This is completed online using the BSA E-Filing System. If you are filing personally, you do not need to pre-register and you can complete the entire process online.

Again, itโ€™s important to note that the threshold for having reportable accounts is aggregate. This means the total value of all of your foreign accounts combined. So, if you have four foreign accounts with only USD 100 and one other foreign account with USD 20,000, all of your financial accounts will need to be reported.

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Frequently Asked Questions

Below are a few of the most common questions we receive from people looking into what a FinCEN Form 114 is. If you have further questions you would like to ask our team, donโ€™t hesitate to get in touch.

What Is 114 Filing Requirement?

114 filing requirement refers to submitting an FBAR (Report of Foreign Bank and Financial Accounts) using FinCEN Form 114. This reporting requirement applies to anyone with foreign financial accounts with an aggregate value of USD 10,000 at any point during the year.

What Is the Difference Between FBAR and FinCEN 114?

The difference between FBAR and FinCEN 114 is that FBAR refers to the reporting of reportable foreign financial accounts while FinCEN Form 114 is the actual form you will submit to comply with this reporting requirement. In other words, in order to comply with FBAR filing requirements, a US person needs to submit FinCEN Form 114.

Can I File an FBAR Myself?

Yes, you can file an FBAR by yourself using the Financial Crime Enforcement Networkโ€™s BSA E-Filing System directly through their website. In fact, as an individual, you do not need to pre-register for the reporting. However, accountants and other professionals looking to file on behalf of others will need to pre-register.

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