If you are a US citizen or green card holder with financial accounts outside the United States, you are almost certainly required to file an FBAR (Foreign Bank and Financial Accounts Report). For digital nomads using Wise, Revolut, N26, or any local bank account abroad, this is not optional. The penalties for non-filing are severe: up to $10,000 per violation for non-willful failures and up to $100,000 or 50% of the account balance for willful violations.
This guide explains the FBAR for digital nomads in plain English.
What Is the FBAR?
The FBAR is FinCEN Form 114, filed electronically with the Financial Crimes Enforcement Network (a bureau of the US Treasury). It is separate from your tax return. The FBAR reports the existence and maximum balance of your foreign financial accounts. It does not result in any tax being owed by itself, but failure to file triggers penalties independently of your tax situation.
The legal authority comes from the Bank Secrecy Act, which requires US persons to report foreign financial accounts to help detect money laundering, tax evasion, and other financial crimes.
Who Must File?
You must file an FBAR if you are a US person (citizen, green card holder, or resident alien), you had a financial interest in or signature authority over at least one foreign financial account, and the aggregate value of all your foreign accounts exceeded $10,000 at any point during the calendar year.
The $10,000 threshold is across all accounts combined. If you have $6,000 in Wise, $3,000 in Revolut, and $2,000 in a Thai bank account, your aggregate is $11,000 and you must file.
Which Accounts Count?
Yes, these count as foreign accounts:
- Wise (registered in Belgium)
- Revolut (registered in Lithuania or UK depending on your account)
- N26 (registered in Germany)
- Any local bank account you open abroad
- Savings accounts at foreign institutions
- Foreign brokerage accounts
- Foreign pension or retirement accounts
No, these do not count:
- US bank accounts (Chase, Schwab, etc.) even if accessed from abroad
- US brokerage accounts
- Crypto wallets (FBAR does not currently cover crypto, though a separate reporting requirement may apply under FATCA)
- Credit card accounts with a zero or negative balance
The $10,000 Threshold Trap
The threshold is based on the highest aggregate balance at any point during the year, not the year-end balance. If your Wise account briefly held $12,000 on March 3rd because a client paid you before you transferred the money out, you must file even if the account held $500 for the rest of the year.
This catches many nomads who receive a large payment into Wise or Revolut and move it to a US account within days. The momentary balance still counts.
How to File
FBAR is filed electronically through the BSA E-Filing System. It is free. You do not need a tax preparer to file it, though many expat tax preparers include FBAR filing in their packages.
What you need:
- Your SSN or ITIN
- The name and address of each foreign financial institution
- Account numbers
- The maximum balance during the year in USD (use the Treasury’s official exchange rate for December 31)
Deadline: April 15, with an automatic extension to October 15. No extension request is needed.
FBAR vs FATCA (Form 8938)
Nomads often confuse FBAR with FATCA reporting (Form 8938). They are separate requirements with different thresholds:
| FBAR (FinCEN 114) | FATCA (Form 8938) | |
|---|---|---|
| Filed with | FinCEN (Treasury) | IRS (with your tax return) |
| Threshold (living abroad) | $10,000 aggregate | $200,000 on last day OR $300,000 at any point |
| Accounts covered | All foreign financial accounts | Foreign financial assets (broader) |
| Penalty for non-filing | Up to $10,000+ per violation | Up to $10,000+ per violation |
If you meet both thresholds, you file both. The information overlaps but the forms are different and go to different agencies.
Common Mistakes Nomads Make
1. Forgetting Wise and Revolut are foreign accounts. They feel like apps on your phone, but legally they are accounts at foreign financial institutions.
2. Thinking the threshold is per account. It is aggregate across all foreign accounts. Three accounts with $4,000 each = $12,000 aggregate = must file.
3. Not filing because they owe no tax. FBAR is an information return. You file it whether or not you owe tax, whether or not you file a tax return, and whether or not you use the FEIE.
4. Waiting until they are “caught.” The IRS and FinCEN have data-sharing agreements with foreign financial institutions under the Common Reporting Standard (CRS). They likely already know about your accounts. Filing late under the delinquent FBAR submission procedures is far better than being flagged for non-filing.
How FBAR Fits Into Your Nomad Tax Strategy
FBAR is one piece of the broader tax picture for American nomads. Your complete filing obligations typically include your federal tax return (Form 1040), FBAR if applicable, FATCA (Form 8938) if applicable, FEIE claim (Form 2555), and state tax filing if your home state has income tax.
See our complete American nomad tax guide for how these pieces fit together, and our FEIE vs Foreign Tax Credit guide for choosing the right exclusion strategy.
Take the WhereToNomad quiz to find tax-free destinations that simplify your local tax burden while you handle the US side.
Also read: Digital Nomad Taxes for Americans | Foreign Earned Income Exclusion Guide | Best Expat Tax Preparers | Best Bank Accounts for Nomads
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