FinCEN Form 114: What It Is and How It Affects Crypto Users

When you hold crypto in a foreign exchange or wallet, you might be required to file FinCEN Form 114, a mandatory report for U.S. persons with foreign financial accounts exceeding $10,000 at any point during the year. Also known as the FBAR (Foreign Bank Account Report), this form is enforced by the Financial Crimes Enforcement Network, a division of the U.S. Treasury. It doesn’t ask what type of asset you hold—Bitcoin, Ethereum, or stablecoins—all count if they’re stored overseas. The IRS treats crypto like property, but FinCEN treats it like cash in a foreign bank. That’s why ignoring this form can cost you $10,000 per violation, even if you didn’t earn a cent.

FinCEN Form 114 isn’t about taxes—it’s about transparency. If you use Binance, Kraken, or any platform outside the U.S. to store crypto, and your total balance across all accounts hit $10,000 at any time last year, you’re on the hook. This includes custodial wallets like Coinbase if they’re based abroad. Non-custodial wallets like MetaMask? Only if they’re hosted on a foreign server or managed by a foreign entity. The key is control and location, not whether you sold anything. Many people think crypto is private or untrackable, but FinCEN gets data from exchanges, blockchain analytics firms, and even foreign governments under CRS and FATCA rules. These international reporting standards now tie directly to your crypto activity.

Related entities like FBAR, the common name for FinCEN Form 114, used by taxpayers and accountants to refer to the filing, and CRS, the Common Reporting Standard that forces financial institutions worldwide to share account data with tax authorities, are part of the same system. You can’t file one without understanding the other. The IRS, the U.S. tax agency that works with FinCEN to track unreported crypto has been actively matching FBAR data with crypto transaction records from exchanges like Coinbase and Kraken. If you moved $15,000 worth of ETH to a wallet in Singapore and forgot to report it, you’re not just being careless—you’re exposing yourself to criminal penalties.

There’s no gray area here. The form is due April 15th, with an automatic extension to October 15th, but no extensions for payment. You file electronically through the BSA E-Filing System, not through your tax return. Most people think TurboTax or H&R Block handles it—they don’t. You need a separate login. And if you’re a U.S. citizen living abroad, you’re still required to file. Dual citizens, green card holders, even long-term residents—everyone falls under this rule. The crypto boom made this harder to ignore. People now hold millions in foreign wallets, thinking they’re safe. They’re not.

Below, you’ll find real examples of how crypto users got caught, what exchanges report to regulators, and how to stay compliant without overcomplicating your life. These aren’t theoretical guides—they’re based on actual cases, filings, and enforcement actions from 2023 and 2024. Whether you’re holding a few thousand or managing a portfolio across multiple jurisdictions, this collection gives you the facts you need before the next deadline hits.