Which foreign accounts need to be reported on FBAR?

A wide range of foreign financial accounts must be reported on FBAR if the aggregate value exceeds $10,000. The definition of 'financial account' is broader than many people expect, and it is important to understand which accounts are included to avoid inadvertent non-compliance.

Bank accounts are the most obvious category — this includes checking accounts, savings accounts, and time deposits (CDs) held at any financial institution located outside the United States. This applies regardless of whether the account earns interest or is used frequently.

Securities and brokerage accounts held at foreign financial institutions must also be reported, including accounts holding stocks, bonds, mutual funds, ETFs, and other investment securities. If a foreign broker holds your investment portfolio, the entire account value is reportable.

Foreign pension and retirement accounts are often reportable, though this is one of the most complex areas. Many foreign pension plans, superannuation accounts (such as Australian super), and mandatory retirement savings programs (like the UK's NEST) are considered financial accounts for FBAR purposes. However, the treatment can vary by country and by the specific type of plan.

Other reportable accounts include: foreign life insurance policies with cash value, accounts with a foreign financial advisor or money manager, foreign mutual fund accounts, accounts at foreign branches of US banks, and accounts at foreign entities that operate as banks even if not formally licensed as such.

Accounts where you have signature authority — meaning you can control the disposition of funds even if you are not the owner — must also be reported. This commonly affects people who have authority over business accounts, accounts for elderly parents, or accounts for organizations they manage.

Notably, direct ownership of foreign real estate is not reportable on FBAR (though it may be reportable on Form 8938 if held through a foreign entity). Foreign cryptocurrency held on foreign exchanges is an evolving area — FinCEN proposed including it, and recent guidance suggests virtual currency accounts at foreign exchanges should be reported.