Crypto FBAR Requirements: What You Must Know About Reporting Foreign Crypto Holdings

When you hold cryptocurrency on a foreign exchange or wallet, you might be required to file an 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 reporting rule that applies to any foreign account holding more than $10,000 at any point during the year, including crypto. Many people think if they didn’t sell their Bitcoin or Ethereum, they don’t owe anything. That’s wrong. FBAR isn’t about gains—it’s about ownership.

The FinCEN, the U.S. government agency that tracks financial crimes and enforces anti-money laundering laws treats crypto like cash when it’s held overseas. If you use Binance, Kraken, or any platform based outside the U.S. and your total crypto balance across all accounts hit $10,000—even for one day—you have to file. This includes wallets you control but aren’t on a U.S.-based exchange. It doesn’t matter if you’re just holding, staking, or using DeFi. The rule applies.

People who ignore this aren’t just risking fines—they’re risking jail. The penalty for willfully not filing can be up to $100,000 or 50% of the account balance, whichever is higher. And it’s not rare: the IRS has been targeting crypto holders since 2020, cross-checking exchange data with FBAR filings. In 2023 alone, over 1,200 crypto-related FBAR cases were referred for criminal review. You don’t need to be a millionaire to get caught. One person who held $15,000 in ETH on a Singapore-based exchange and didn’t file got fined $75,000.

It’s not just about exchanges. If you use a non-U.S. wallet like Trust Wallet, Phantom, or MetaMask connected to a foreign node, and your holdings cross the $10,000 threshold, you’re in scope. The key is control: if you hold the private keys and the service provider is outside the U.S., it counts. The IRS doesn’t care if you call it a "wallet" or an "account." If it’s foreign and you own it, it’s reportable.

Some think the U.S. government can’t track foreign crypto. That’s outdated. U.S.-based exchanges like Coinbase and Kraken now report user data to the IRS under FATCA. Foreign exchanges that deal with Americans are pressured to share data too. And if you use a VPN to hide your location? That doesn’t erase the obligation—it just makes the risk worse.

What about crypto held in a U.S.-based wallet but accessed from abroad? That’s not reportable. The location of the wallet provider matters, not where you are. If your Coinbase account is in the U.S., even if you’re traveling in Thailand, you’re fine. But if you moved your crypto to a Swiss-based exchange and never reported it? You’re in trouble.

You don’t need to be rich to trigger this. A $5,000 Bitcoin purchase in 2021 and a $7,000 Ethereum stake in 2022 add up to $12,000. That’s a filing requirement. The clock resets every day. If your balance crossed $10,000 on June 15, even if it dropped to $2,000 the next day, you still file.

Below are real cases and guides on how crypto regulations affect your reporting duties—from how UAE tax laws interact with FBAR to how Australian and German rules stack up. You’ll find what happens when you ignore the rules, how to fix past mistakes, and what platforms are safest if you want to stay compliant. This isn’t about fear—it’s about clarity. If you own crypto overseas, you need to know this.