Crypto FBAR Requirements: What You Must Report and Why It Matters

When you hold crypto on a foreign exchange or wallet, you might be required to file a FBAR, a financial report filed with the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) to disclose foreign financial accounts. Also known as FinCEN Form 114, it’s not a tax form—it’s a disclosure rule that applies even if you didn’t sell a single coin. If your total crypto holdings across all foreign platforms hit $10,000 at any point in the calendar year, you’re legally required to report them. This includes exchanges like Binance (outside the U.S.), Kraken (if you’re not a U.S. resident), or even wallets hosted on foreign servers. The IRS doesn’t care if you made a profit. They care if you had access to it overseas.

Many people think crypto is anonymous or that holding it in a non-custodial wallet avoids reporting. That’s not true. If the wallet is hosted by a foreign company—or if you control it from abroad—it counts. The same goes for staking on a foreign DeFi platform or holding tokens on a non-U.S. exchange. FinCEN, the agency that enforces FBAR rules and tracks cross-border financial activity treats crypto like cash in a foreign bank. And IRS crypto compliance, the system that ties FBAR filings to tax returns and audits is getting sharper. They’re matching data from foreign exchanges, blockchain analytics, and even whistleblower tips. In 2024, the IRS sent out over 12,000 crypto-related audit letters. Most of them started with an unreported FBAR.

It’s not just about fines. Willful failure to file can cost you up to 50% of your total foreign account balance per year—plus criminal charges. Even if you didn’t know the rule, the penalty for non-willful violations is $10,000 per missed form. That’s not a typo. You can’t claim ignorance if you traded on Binance, Kraken, or any platform not based in the U.S. And yes, this applies even if you only held crypto for one day. The threshold is a snapshot: if your balance crossed $10,000 on June 15th, you owe a report.

What counts as a foreign account? Any exchange, wallet, or service not headquartered in the United States. That includes custodial wallets on foreign platforms, non-custodial wallets where the private keys are stored overseas, or even staking rewards earned on a platform based in Singapore, Germany, or Canada. The rule doesn’t care if you’re a casual holder or a full-time trader. If you’re a U.S. person—citizen, green card holder, or resident alien—and your total foreign crypto value hit $10,000, you’re in scope.

Most people don’t file because they don’t realize they need to. They think taxes are the only thing that matters. But FBAR is separate from Form 8949 and Schedule D. You can file your taxes perfectly and still get hit for skipping the FBAR. The deadline is April 15th, with an automatic extension to October 15th. No need to ask. Just file.

Below, you’ll find real cases and clear breakdowns of how crypto reporting works under U.S. law—what triggers it, what gets missed, and how people got caught. You’ll see how Brazil’s crypto rules, OFAC sanctions, and Chinese crypto bans don’t change your U.S. reporting duty. Whether you’re holding tokens from a failed airdrop or trading on a tiny exchange, if it’s foreign and over $10,000, it’s reportable. Don’t wait for a letter. Know your obligation before it’s too late.