# FBAR and FATCA: reporting foreign bank accounts, including Russian ones

File an FBAR if your foreign accounts topped $10,000 combined. Who files, how to count, April 15 and October 15 deadlines, Form 8938 and penalties.

FBAR and FATCA are two separate reports on foreign bank accounts for US tax residents. You file an FBAR (FinCEN Form 114) if the combined maximum balances of all your accounts abroad went over $10,000 at any point in the year. Form 8938 (the FATCA form) goes with your tax return and has much higher thresholds, starting at $50,000. Accounts at Russian banks count.

Below: who has to file, which accounts go on the report, how to file the FBAR online and what to do if your bank in Russia is under sanctions.

## Who has to file an FBAR

A "United States person" files if they have a financial interest in, or signature authority over, a foreign financial account. Under the [FinCEN filing rules](https://www.fincen.gov/report-foreign-bank-and-financial-accounts), US persons are:

- US citizens, including minor children;
- US residents, meaning foreign nationals living here who are residents under the tax tests in section 7701(b) of the Internal Revenue Code;
- companies, partnerships, LLCs, trusts and estates formed under US law.

For immigrants this usually works out like this: a green card holder is a US person and files if their accounts pass the threshold. A person on a work visa who has spent enough days in the US to become a tax resident under the substantial presence test is a US person too. If you are not sure of your tax status for a given year, start with our [tax basics for new immigrants](/en/immigration/tax-basics-new-immigrants-usa).

Financial interest means you are the owner of record, even if the money is really "for mom". Signature authority means you can move money by giving the bank instructions. A common case: a power of attorney over an elderly parent's account at Sberbank or at a bank in Kazakhstan. That account goes on the report too.

Children are responsible for their own FBAR. If a child cannot file, for example because of age, a parent or guardian files for them.

## Which accounts count: Russian banks, brokers, insurance

FinCEN defines a financial account broadly: checking, savings, deposit, time deposit, brokerage, securities or any other account at a financial institution. That includes:

- card accounts at Russian banks;
- deposits and savings accounts;
- brokerage and investment accounts;
- an insurance policy with a cash value, such as whole life;
- an annuity with a cash value;
- shares in a mutual fund open to the public.

An account is foreign if it is located outside the United States. A branch of a US bank abroad is foreign. A US branch of a foreign bank is not.

It does not matter whether the account earns income. A zero-interest deposit or a forgotten card that receives a parent's pension still counts toward the threshold.

The exceptions the IRS lists include correspondent accounts, accounts owned by government entities or international financial institutions, accounts at US military banking facilities and, under certain conditions, retirement accounts (IRAs and employer plans). Accounts at sanctioned banks are not on that list.

## How to work out the $10,000 threshold

The threshold is aggregate. Add up the maximum balance of each foreign account during the calendar year; if the total went over $10,000, you file.

1. Find each account's maximum balance for the year in the account's currency. Statements are fine if they fairly show the maximum.
2. Convert to dollars at the Treasury Reporting Rates of Exchange for the last day of the year, published quarterly on [fiscaldata.treasury.gov](https://fiscaldata.treasury.gov/datasets/treasury-reporting-rates-exchange/treasury-reporting-rates-of-exchange). If there is no Treasury rate for a currency, use another verifiable rate and give its source.
3. Round up to the next whole dollar and add the accounts together.

Example: a ruble account peaked at the equivalent of $7,000 and a brokerage account at $4,000. Neither is over the threshold alone, but together they make $11,000. You file an FBAR and list both.

Spouses with joint accounts usually each file their own FBAR, each reporting the full value of the joint account. The exception: all of your accounts are joint with your spouse, your spouse files on time, and you both signed Form 114a (the e-filing authorization). Then one report is enough.

## FBAR vs Form 8938 (FATCA)

Form 8938 does not replace the FBAR. Many people need both, and the same account can appear on each.

| | FBAR (FinCEN 114) | Form 8938 |
|---|---|---|
| Who files | US persons: citizens, residents, entities, trusts | Citizens, tax residents, certain nonresidents and entities |
| Where | FinCEN, online through BSA E-Filing, separate from the tax return | IRS, attached to the tax return |
| Threshold | Over $10,000 combined at any time in the year | Depends on filing status and where you live (below) |
| What goes on it | Financial accounts at foreign institutions | Accounts plus foreign securities and interests held outside an account |
| Due | April 15, automatic extension to October 15 | The tax return due date, including extensions |

Form 8938 thresholds:

| Situation | More than, last day of year | More than, any time in year |
|---|---|---|
| Living in the US, single or married filing separately | $50,000 | $75,000 |
| Living in the US, married filing jointly | $100,000 | $150,000 |
| Living abroad, single or married filing separately | $200,000 | $300,000 |
| Living abroad, married filing jointly | $400,000 | $600,000 |

Thresholds and deadlines checked October 28, 2026 on irs.gov and fincen.gov.

A few details from the [Form 8938 instructions](https://www.irs.gov/instructions/i8938) and the [IRS questions and answers on Form 8938](https://www.irs.gov/businesses/corporations/basic-questions-and-answers-on-form-8938):

- if you do not have to file a tax return, you do not file Form 8938, but you may still owe an FBAR;
- if you became a resident partway through the year, the 8938 reporting period starts on your residency date;
- foreign social security is not reported on Form 8938, while an interest in a foreign pension plan is;
- foreign currency you hold yourself, real estate you own directly and a safe deposit box do not go on Form 8938.

## Deadlines and filing through BSA E-Filing

The FBAR for a year is due April 15 of the following year. If you miss that date, you get an automatic extension to October 15 without asking. The 2025 FBAR was due by October 15, 2026. The 2026 FBAR is due April 15, 2027, with the automatic extension to October 15, 2027.

The FBAR is filed only online, through FinCEN's BSA E-Filing System. Individuals do not need to register. It does not go with your tax return, and paper filing requires an exemption from FinCEN. If an accountant or CPA files for you, they register as an institution and you sign Form 114a. You can find a Russian-speaking one in our [accountant directory](/en/directory/accountants).

For each account you will need:

- the name on the account;
- the account number;
- the bank's or broker's name and address;
- the type of account;
- the maximum value during the year.

Under IRS rules these records are generally kept for 5 years from the FBAR due date. A copy of the filed FBAR helps meet that rule.

## Accounts at sanctioned banks: reporting is not permission

An FBAR only reports that an account exists. It does not authorize anything: OFAC sanctions rules apply separately. If your Russian bank is blocked under Executive Order 14024, dealings with it are generally prohibited for US persons. You can check a specific bank in OFAC's Sanctions List Search.

OFAC issued [General License 50](https://ofac.treasury.gov/media/925326/download?inline), dated August 19, 2022. It authorizes closing the account of an individual who is not a blocked person at a bank blocked under EO 14024, and a lump sum transfer of the remaining funds to the account holder, including to their own account at a non-blocked bank. It does not authorize dealings with other blocked persons unless separately authorized, or anything prohibited by Directive 4 (the Central Bank of Russia, the National Wealth Fund and the Russian Ministry of Finance). Other general licenses for the Russia program are on the [OFAC program page](https://ofac.treasury.gov/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions).

Workarounds for moving money out (crypto, cards from third countries, couriers) carry a direct risk of violating US sanctions, and we do not cover them. For legal options, see [how to send money to Russia and Ukraine](/en/immigration/send-money-russia-ukraine-usa).

## Penalties and what to do if you never filed

The IRS says filing an FBAR late or not at all is a violation that may bring civil and criminal penalties, depending on the facts.

| Violation | Maximum penalty per the IRS |
|---|---|
| FBAR, non-willful | up to $10,000 (base amount, adjusted for inflation) |
| FBAR, willful | greater of $100,000 or 50% of the balances (base, adjusted) |
| Form 8938 not filed | $10,000, plus up to $50,000 more for continuing after an IRS notice |
| Underpaid tax tied to an undisclosed asset | 40% of the underpayment |

Amounts checked October 28, 2026 on irs.gov. The IRS notes that FBAR amounts are adjusted for inflation every year.

There is one more consequence: if Form 8938 is not filed, the time the IRS has to assess tax for that year can stay open until 3 years after you file it.

On its FBAR page the IRS says a late FBAR should be filed as soon as possible, with the reason for filing late explained as FinCEN's instructions describe. For people who have not reported foreign assets for years, the IRS lists three options: the IRS Criminal Investigation Voluntary Disclosure Practice, the Streamlined Filing Compliance Procedures and the delinquent international information return submission procedures. The IRS encourages taxpayers to choose with a tax or legal advisor. That matters most when the accounts produced income that never made it onto a return, when the amounts are large or when the failure may have been willful: in those cases people see a professional before filing anything late. Russian-speaking attorneys are in our [lawyer directory](/en/directory/lawyers).

## Questions people ask

### Do I report a Sberbank card that receives my parents' pension?

Yes, if you are the owner of the account or have signature authority, for example through a power of attorney, and the combined maximum balance of all your foreign accounts went over $10,000 during the year. FinCEN's exceptions do not include money that belongs to relatives or accounts that earn nothing.

### Can I file the FBAR with my tax return?

No. The FBAR is filed separately and electronically through FinCEN's BSA E-Filing System and is not attached to the tax return. It is due April 15 with an automatic extension to October 15. Form 8938, by contrast, is attached to the tax return and goes to the IRS.

### I am on a work visa. Do I need to file an FBAR?

Yes, if for that year you are a US tax resident under the substantial presence test and the combined maximum balances of your foreign accounts went over $10,000. A nonresident for tax purposes is generally not a US person for FBAR. Your status is decided year by year.

### Is filing an FBAR for an account at a sanctioned bank a violation?

No. The FBAR only reports that the account exists; it is not a transaction with the bank. Dealings with a blocked bank are governed by OFAC, and OFAC General License 50 lets an individual close their own account at a bank blocked under EO 14024 and move the balance to themselves in one lump sum.

## Sources

- [IRS: Report of Foreign Bank and Financial Accounts (FBAR)](https://www.irs.gov/businesses/small-businesses-self-employed/report-of-foreign-bank-and-financial-accounts-fbar)
- [IRS: Comparison of Form 8938 and FBAR requirements](https://www.irs.gov/businesses/comparison-of-form-8938-and-fbar-requirements)
- [IRS: Instructions for Form 8938](https://www.irs.gov/instructions/i8938)
- [IRS: Basic questions and answers on Form 8938](https://www.irs.gov/businesses/corporations/basic-questions-and-answers-on-form-8938)
- [IRS: Options for US taxpayers with undisclosed foreign financial assets](https://www.irs.gov/individuals/international-taxpayers/options-available-for-us-taxpayers-with-undisclosed-foreign-financial-assets)
- [FinCEN: Report Foreign Bank and Financial Accounts](https://www.fincen.gov/report-foreign-bank-and-financial-accounts)
- [FinCEN: BSA Electronic Filing Requirements for FinCEN Form 114](https://www.fincen.gov/sites/default/files/shared/FBAR%20Line%20Item%20Filing%20Instructions.pdf)
- [Treasury: Treasury Reporting Rates of Exchange](https://fiscaldata.treasury.gov/datasets/treasury-reporting-rates-exchange/treasury-reporting-rates-of-exchange)
- [OFAC: Russian Harmful Foreign Activities Sanctions](https://ofac.treasury.gov/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions)
- [OFAC: General License No. 50](https://ofac.treasury.gov/media/925326/download?inline)

Page: https://www.russiansinusa.com/en/immigration/fbar-fatca-foreign-bank-accounts
Facts checked: 2026-10-28