Crypto FBAR Requirements: What You Must Report to the IRS
When you hold cryptocurrency on a foreign exchange or wallet, you might be required to file an FBAR, a 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 requirement. If your total foreign crypto holdings exceeded $10,000 at any point during the year, you’re legally required to file, no matter if you sold, traded, or just held it.
The IRS treats crypto like property, but FBAR rules treat it like cash in a foreign bank. That means if you had $8,000 on Binance and $3,000 on Kraken—both based outside the U.S.—you’ve hit the $10,000 threshold. It doesn’t matter if the accounts are in your name, your spouse’s, or even a trust. What matters is control: if you can move the crypto without someone else’s approval, it counts. And yes, that includes self-custody wallets if they’re hosted on servers outside the U.S. Many people think if they didn’t cash out, they’re safe. They’re not. FBAR isn’t about gains—it’s about presence.
Not filing can cost you more than you own. For non-willful violations, penalties start at $10,000 per year. For willful ones? Up to 50% of your total foreign account balance—or $100,000, whichever is higher. The IRS now cross-references data from exchanges like Coinbase and Binance with IRS tax returns. If you reported crypto income but didn’t file FBAR, you’re already on their radar. Even if you didn’t earn a cent, just holding crypto overseas triggers the rule. This isn’t theoretical—thousands of Americans have been fined for missing this step, often because they assumed crypto was too new to matter.
There’s no gray area: if the exchange or wallet provider is based outside the U.S., and you had more than $10,000 across all your foreign crypto accounts at any time during the year, you need to file. The deadline is April 15, but you get an automatic extension to October 15. No form needed to request it—just file by then. You file electronically through the BSA E-Filing System, not the IRS portal. And yes, you must report every single foreign account, even if one had $50 and another had $9,950. Add them all up.
You’ll find posts here that explain how crypto regulations are changing in the EU under MiCA, how Indian traders use UPI to buy Bitcoin, and how DeFi protocols track value locked. But none of those matter if you’re not compliant with U.S. law. This collection gives you real-world examples of what triggers FBAR, how people got caught, and how to fix past mistakes before the IRS comes knocking. You won’t find fluff here—just what you need to avoid a penalty that could wipe out your entire crypto portfolio.
FBAR Requirements for Crypto Accounts Over $10,000 in 2025
Understand FBAR rules for crypto accounts over $10,000 in 2025. Learn when you must file, how to calculate your balance, and whether to file even if the law doesn't require it yet.
- April 15 2025
- Terri DeLange
- 11 Comments