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FinCEN Form 114 · FBAR

Which part of the FBAR does your account go in?

The FBAR has separate Parts for accounts you own, accounts you share, and accounts you can only sign on. Answer the questions below for one account at a time to see where it belongs. The questions apply to whoever is filing, whether that’s a person or a company, partnership, trust, or estate.

First, do you file at all?

All three must be true. If any one isn’t, you don’t have an FBAR to file for the year.

Work through the tree

Answer for one account at a time. The tree stops when an answer leads to a Part.

Start with question A, or pick a situation under “What goes in each Part” further down.

A1010.350(e)(1)

Is your name on the account?

You’re the owner of record or hold legal title. This counts even when the money is held for someone else’s benefit.

Yes, only mine
Part IIOwned separately

Items 15–23 describe the account. FinCEN Form 114 instructions

Yes, with others
Part IIIOwned jointly

Each joint owner reports the account’s full value. Items 15–23 describe the account. FinCEN Form 114 instructions Item 24 gives the number of joint owners, not counting you, or an estimate if you don’t know the exact number. FinCEN Form 114 instructions Items 25–33 identify the principal joint owner other than you, which can be a company; leave blank any of these items for which no information is available. FinCEN Form 114 instructions If your spouse has an interest in the account, your spouse is the principal joint owner. FinCEN Form 114 instructions Spouses can file a single FBAR only if every account the non-filing spouse would have to report is held jointly with the filing spouse, the filing spouse reports those accounts on a timely filed FBAR, and both sign Form 114a. FinCEN Form 114 instructions, p. 16

No
B1010.350(e)(2)(i)

Does someone hold the account for you?

The owner on record is your agent, nominee, attorney, or someone else acting for you on this account.

  • Your employee holds it in their own name for you: answer Yes. The employee reports it too, under question A, because their name is on it. 1010.350(e)(2)(i), (e)(1)
  • Your company holds it: answer Yes only if the company holds it purely as your nominee, which a company can be. If it’s the company’s own account, used in its business, answer No and let question C settle it by how much of the company you own. 1010.350(e)(2)(i), 1010.100(mm), (e)(2)(ii)
Yes
Part IIOwned separately

You report it as your own account. Items 15–23 describe the account. FinCEN Form 114 instructions

No
C1010.350(e)(2)(ii), (e)(3)

Do you own more than 50% of the entity that holds it?

Count what you own directly and through other entities. Any one of these measures is enough:

  • Corporation, including an S corporation: voting power or total share value
  • Partnership: profits or capital
  • Any other entity, including an LLC: voting power, equity value or assets, or profits

Exactly 50% isn’t enough, and a relative’s shares aren’t added to yours. An entity set up to avoid FBAR reporting is treated as yours.

Yes
Part IIOwned separately

Report the account’s full value, not your ownership percentage. Items 15–23 describe the account. FinCEN Form 114 instructions

Yes, consolidating
Part VConsolidated report

Optional, and only for a U.S. entity. It can report its own accounts on one FBAR together with those of U.S. entities it owns more than 50% of, directly or indirectly. 31 CFR 1010.350(g)(3), FinCEN Form 114 instructions Check box 2d in Part I. FinCEN Form 114 instructions, p. 20 Items 15–23 describe the account. FinCEN Form 114 instructions Items 34, 35 and 38–42 identify the entity that owns the account: its name as the financial institution’s books show it, its TIN and its mailing address. FinCEN Form 114 instructions If the entities in the report have a financial interest in 25 or more accounts, complete only these Part V items, once for each entity included in the report. FinCEN Form 114 instructions, p. 20

No
D1010.350(e)(2)(iii)–(iv), (g)(5)

Is it held by a trust you own or mostly benefit from?

You’re the grantor treated as the trust’s owner for income tax purposes, you have a present interest in more than 50% of its assets, or you receive more than 50% of its current income.

Yes
Part IIOwned separately

Items 15–23 describe the account. FinCEN Form 114 instructions A beneficiary is excused if the trust, its trustee, or its agent is a U.S. person that reports the account. 31 CFR 1010.350(g)(5), FinCEN Form 114 instructions

No
E1010.350(f)(1)

Will the bank act on your instructions?

You can move or withdraw the money by contacting the bank directly, alone or together with another signer. What matters is what the bank will accept from you, not your title or how much of the company you own. Only individuals have signature authority. 76 FR 10236

Counts

  • You’re on the account’s signature card or bank mandate, even if you never use it
  • Your online banking login lets you send wires or transfers yourself
  • The bank needs two signers and you’re one of them
  • The bank honors your power of attorney over someone else’s account

Doesn’t count by itself

  • Owning shares, whether 30% or 49%, without being on the signer list
  • Approving payments inside the company while someone else instructs the bank
  • Supervising the people who sign
  • View-only online access to statements
No
NoneNot reportable by you

You have nothing to report for this account. 31 CFR 1010.350(a)

Yes
F1010.350(f)(2), FinCEN Form 114 instructions

Does a signature-authority exception cover you?

These apply only if you have no financial interest in the account, and only to officers and employees of:

  • a federally examined bank, for the bank’s own accounts 1010.350(f)(2)(i)
  • a financial institution registered with and examined by the SEC or CFTC, for its own accounts (f)(2)(ii)
  • an SEC-registered service provider, for accounts of a registered investment company it serves (f)(2)(iii), 76 FR 10241
  • a company with stock listed on a U.S. exchange, for the company’s own accounts (f)(2)(iv)
  • a U.S. subsidiary of a U.S. parent with stock listed on a U.S. exchange, for the subsidiary’s own accounts, when the parent’s consolidated FBAR includes the subsidiary (f)(2)(iv)
  • a company with stock registered under Securities Exchange Act § 12(g), for the company’s own accounts (f)(2)(v)
Yes
NoneNot reportable by you

The exception covers this account. 31 CFR 1010.350(f)(2), FinCEN Form 114 instructions

No
Part IVSignature authority, no financial interest

Items 15–23 describe the account, items 34–42 identify the account’s owner, and items 43 and 45 give your title. FinCEN Form 114 instructions, p. 19, p. 20 If the account has more than one owner, items 34–42 identify the principal joint owner other than you. FinCEN Form 114 instructions A U.S. person living abroad who signs on the account of an employer located abroad completes only Part I and items 34–43, once, with the employer’s details. FinCEN Form 114 instructions

What counts as a foreign account

Counts

Doesn’t count

  • An account at a financial institution located in the U.S., including a U.S. branch of a foreign bank, even if it holds foreign stocks or currency76 FR 10235, FinCEN Form 114 instructions
  • Foreign assets held in a U.S. custodian’s pooled account that you can’t access directly76 FR 10235
  • Property you own directly rather than through an account, such as foreign real estate1010.350(c)
  • Interests in private funds, such as hedge funds and private equity funds. The rule holds this category for future guidance, so they aren’t reportable for now.1010.350(c)(3)(iv)(B)
  • Correspondent accounts that banks keep with each other to settle payments1010.350(c)(4)(iv)
  • Accounts of U.S. federal, state, local, or tribal governments; accounts of international financial institutions the U.S. belongs to; and accounts at U.S. military banking facilities abroad1010.350(c)(4)(i)–(iii)
  • Foreign accounts held inside your IRA, or inside a 401(a), 403(a), or 403(b) plan you participate in1010.350(g)(4)

Payment apps like Airwallex and Wise

Airwallex and Wise aren’t banks, but the FBAR rule also covers accounts with businesses that hold customer money, so their accounts can still count as foreign accounts. The deciding factor is the company that holds your account, not the currency it’s in. FinCEN hasn’t issued guidance on these services by name.31 CFR 1010.350(c)(3)(i), 76 FR 10235

Both companies keep customer money at partner banks, but your account is with Airwallex or Wise, not the partner bank. The money usually sits in pooled accounts in the provider’s name. FinCEN treats a similar pooled arrangement as not foreign unless you can reach the money at the foreign institution directly. Local account details issued in your own name at a foreign bank look more like direct access.76 FR 10235, Airwallex US Payment and FX Terms, Wise: how Wise US Inc. protects customer funds

Airwallex

  • U.S. businesses usually sign up with Airwallex US, LLC. Its U.S. dollar account is generally not foreign.Airwallex US Service Agreement
  • Balances in other currencies are a gray area. Airwallex’s U.S. terms say its affiliates may create the account details for other currencies, without naming them.Airwallex US Payment and FX Terms
  • An account opened with an Airwallex company outside the U.S., such as in Australia or the UK, is foreign.76 FR 10235

Wise

  • U.S. customers usually hold their account with Wise US Inc., a U.S. money transmitter that keeps customer money mainly at JPMorgan Chase. That account is generally not foreign.Wise: how Wise US Inc. protects customer funds
  • Wise doesn’t say where Wise US Inc. holds balances in other currencies, and tax professionals differ on whether to report them. Greenback Tax Services says Wise’s non-USD balances are held at partner banks outside the U.S. and are reportable. Taxes for Expats says an account held with Wise US Inc. isn’t a foreign account and doesn’t trigger an FBAR.Wise: how Wise US Inc. protects customer funds, Greenback Tax Services, Taxes for Expats
  • An account opened with one of Wise’s companies outside the U.S. is foreign, even for U.S. dollar balances with a U.S. routing number.76 FR 10235

How to check: the account agreement in the app names the company you are contracted with. A business can have more than one, such as one for each region. If it’s still unclear, listing the account is the safer choice. There’s no penalty for reporting an account that turns out not to be required.

What goes in each Part

Where everyday accounts end up, Part by Part, each with a link to trace it on the tree, and the edge cases for that Part. Whichever Part it is, report the account’s highest value during the year, whatever share of it you own. FinCEN Form 114 instructions, p. 17, p. 18

Part IIOwned separately

Common situations

  • An account in your own name
  • An account someone holds for you as your agent or nominee
  • An account held by a company you own more than 50% of
  • An account held by a trust you created and are taxed on as owner
  • An account held by a trust you receive more than half the income from

Edge cases

  • Owning and signingPart IV is only for accounts with no financial interest. If you own more than 50% and also sign, the account goes in Part II and nowhere else. FinCEN Form 114 instructions, p. 18
  • Indirect owners and Part II Judgment callThe instructions don’t say which Part a more-than-50% owner uses for the company’s account. Part II is the answer by elimination, since it excludes only joint, signature-only, and consolidated accounts. FinCEN Form 114 instructions
  • Ownership through layers Judgment callThe rule counts indirect ownership but gives no method for multiplying through layers of entities. When any layer is below 100%, document how you computed the percentage. 31 CFR 1010.350(e)(2)(ii), FinCEN Form 114 instructions
  • Exactly 50%, relatives, and shellsExactly 50% isn’t enough, and a relative’s shares aren’t added to yours. An entity set up to avoid FBAR reporting is treated as yours. 31 CFR 1010.350(e)(2)(ii), (e)(3)
  • 25 or more accountsWith a financial interest in 25 or more accounts, check item 14a, give the count, and skip Parts II and III. FinCEN Form 114 instructions, p. 15 Keep full records of every account for five years. FinCEN Form 114 instructions, p. 8, 76 FR 10236
Part IIIOwned jointly

Common situations

  • A joint account with your spouse
  • A joint account with a relative, a business partner, or anyone else

Edge cases

  • Each owner reports the full valueEach joint owner reports the account’s full value. Item 24 gives the number of joint owners, not counting you, or an estimate if you don’t know the exact number. FinCEN Form 114 instructions
  • The principal joint ownerItems 25–33 identify the principal joint owner other than you, which can be a company; leave blank any of these items for which no information is available. If your spouse has an interest in the account, your spouse is the principal joint owner. FinCEN Form 114 instructions
  • One FBAR for both spousesSpouses can file a single FBAR only if every account the non-filing spouse would have to report is held jointly with the filing spouse, the filing spouse reports those accounts on a timely filed FBAR, and both sign Form 114a, which they keep rather than send to FinCEN. Otherwise each spouse files their own FBAR and reports the joint accounts in full. FinCEN Form 114 instructions, p. 12, p. 16
  • 25 or more accountsWith a financial interest in 25 or more accounts, check item 14a, give the count, and skip Parts II and III. FinCEN Form 114 instructions, p. 15 Keep full records of every account for five years. FinCEN Form 114 instructions, p. 8, 76 FR 10236
Part IVSignature authority only

Common situations

  • An account held by a company you own 50% or less of, where you’re a signer
  • Your employer’s foreign account, where you’re a signer and no exception at question F applies
  • Someone else’s account that the bank lets you act on under a power of attorney

Edge cases

  • No financial interestPart IV is only for accounts with no financial interest. If you own more than 50% and also sign, the account goes in Part II and nowhere else. FinCEN Form 114 instructions, p. 18
  • Only individualsOnly individuals have signature authority, so an entity never reports in Part IV. 76 FR 10236
  • Officers and employees of certain employersThe exceptions at question F (banks, SEC- or CFTC-examined institutions, companies listed on a U.S. exchange and their included subsidiaries, and Securities Exchange Act § 12(g) registrants) take the account out of the FBAR altogether. 31 CFR 1010.350(f)(2), FinCEN Form 114 instructions
  • More than one ownerIf the account has more than one owner, items 34–42 identify the principal joint owner other than you. FinCEN Form 114 instructions
  • Working abroad for a foreign employerA U.S. person living abroad who signs on the account of an employer located abroad completes only Part I and items 34–43, once, with the employer’s details. FinCEN Form 114 instructions
  • 25 or more accountsWith signature authority only over 25 or more accounts, check item 14b and complete just items 34–43 for each owner. FinCEN Form 114 instructions
  • Records and due dateAn officer or employee who signs on an employer’s account doesn’t have to keep the account records personally. FinCEN Form 114 instructions, 76 FR 10236 FinCEN has extended the due date each year for certain individuals with signature authority only; see Deadlines.
Part VConsolidated report

Common situations

  • A subsidiary’s account, reported by the U.S. parent that owns more than 50% of it

Edge cases

  • Optional, and for U.S. entities onlyA U.S. entity can report its own accounts on one FBAR together with those of U.S. entities it owns more than 50% of, directly or indirectly. 31 CFR 1010.350(g)(3), FinCEN Form 114 instructions Check box 2d in Part I. FinCEN Form 114 instructions, p. 20
  • The owner of each accountItems 34, 35 and 38–42 identify the entity that owns the account: its name as the financial institution’s books show it, its TIN and its mailing address. FinCEN Form 114 instructions
  • 25 or more accountsIf the entities in the report have a financial interest in 25 or more accounts, complete only Part V’s owner items, 34, 35 and 38–42, once for each entity included in the report. FinCEN Form 114 instructions, p. 20
  • Covers only the entities namedA consolidated report covers only the U.S. entities named in it. The owners and signers of those entities still file their own FBARs. 31 CFR 1010.350(a), 76 FR 10236, FinCEN Form 114 instructions
  • Officers of an included subsidiaryAn officer or employee of a U.S. subsidiary has nothing to report for the subsidiary’s own accounts when the subsidiary’s U.S. parent has stock listed on a U.S. exchange and includes the subsidiary in its consolidated FBAR. 31 CFR 1010.350(f)(2)(iv)
NoneNot reportable by you

Common situations

  • An account held by a company you own 50% or less of, where you can’t sign
  • Your employer’s foreign account, as an officer of a company listed on a U.S. exchange

Edge cases

Deadlines, records, and penalties

Checked October 23, 2026.

This page is general information about FinCEN Form 114. It isn’t legal or tax advice, and using it doesn’t create a client relationship. Rules and deadlines change, so confirm current requirements before you file.