The FBAR — Report of Foreign Bank and Financial Accounts, formally FinCEN Form 114 — is one of the most misunderstood US filings for expats. It is not part of your tax return, it is filed separately with the US Treasury, and the penalties for missing it are far worse than for tax mistakes.
Who has to file
Any US person — citizen, Green Card holder, or US tax resident — whose aggregate foreign financial accounts exceeded $10,000 USD at any point during the calendar year. The threshold is across the total of all accounts combined, not per account.
What counts as a foreign account
- UK bank accounts (current, savings, joint).
- UK brokerage and investment accounts (Hargreaves Lansdown, AJ Bell, etc.).
- Cash ISAs, Stocks & Shares ISAs, Junior ISAs.
- Workplace pensions, SIPPs, and most personal pensions.
- Premium Bonds and National Savings products.
- Accounts where you have signature authority but no ownership (e.g. for a UK employer or a relative).
How to file
FBAR is e-filed through the BSA E-Filing System — not through your tax return. The deadline is 15 April with an automatic extension to 15 October. There is no form to request the extension, it is automatic.
Penalties
- Non-willful: up to $10,000 per account per year (capped per IRS guidance).
- Willful: greater of $100,000 or 50% of the account balance, per year.
- Criminal: up to $250,000 fine and 5 years imprisonment in the worst cases.