Foreign Accounts Holding Only Virtual Currency Not Reportable on FBAR
Treasury intends to amend FBAR regulations to include virtual currency as a type of reportable account.
Currently, FBAR regulations do not define a foreign account holding virtual currency as a reportable account, unless it holds reportable assets besides virtual currency.
Report of Foreign Bank and Financial Accounts (FBAR)
Filing Requirement for Virtual Currency
FinCEN Notice 2020-2
Currently, the Report of Foreign Bank and Financial Accounts (FBAR) regulations do not define
a foreign account holding virtual currency as a type of reportable account. (See 31 CFR
1010.350(c)). For that reason, at this time, a foreign account holding virtual currency is not
reportable on the FBAR (unless it is a reportable account under 31 C.F.R. 1010.350 because it
holds reportable assets besides virtual currency). However, FinCEN intends to propose to amend
the regulations implementing the Bank Secrecy Act (BSA) regarding reports of foreign financial
accounts (FBAR) to include virtual currency as a type of reportable account under 31 CFR
1010.350.