Do Wise, Revolut and other fintech accounts go on the FBAR?

Yes. The FBAR (FinCEN Form 114) reports financial accounts held at institutions located outside the United States. An e-money or payments account is a financial account, and whether the app feels like a bank is beside the point — what matters is where the institution that holds the balance is located.

The same app can involve different institutions and account locations for different customers. Identify the institution and the branch maintaining the account; parent-company nationality alone does not settle this.

Read the account agreement and statements to identify the maintaining institution and branch. An IBAN prefix, currency or home address alone does not establish the account location.

The table lists provider examples from the existing registry, not a determination of your account. Confirm your own records and the relevant period, including any migration notice.

For a foreign financial account within FBAR scope, test whether relevant foreign accounts in aggregate exceeded $10,000 at any time in the calendar year. A temporarily held transfer can matter. Establish the account location and ownership before applying the threshold.

Once the aggregate crosses the trigger, every non-US account is listed on the FBAR, including ones whose own balance never got anywhere near it.

The FBAR asks for each account's maximum value during the year in US dollars, converted at the Treasury's year-end exchange rate for each currency. Whether a multi-currency account is one line or several depends on how the provider structures it: a single account with currency pockets is usually one account at its combined peak, while balances that carry their own account numbers or IBANs are usually separate accounts, each with its own peak.

Where the structure is unclear, ask the provider whether the currency pockets belong to one account or distinct accounts, and have the reporting reviewed. Do not duplicate the same balance or assume that each currency label creates another account.

Keep the statements and migration notices for both periods. Confirm whether the account itself changed or only the institution's name; an entity change does not automatically create a second reportable account.

Moving to a US-maintained account does not erase a reportable foreign account held earlier that year. Establish the account structure and maximums without duplicating the same balance.

For each account: the name and address of the institution, the account number, the type of account, and the maximum value during the year — with the per-currency statements that show it. Keep the documents that name the holding entity, because that is the fact an examiner would ask you to support.

The FBAR rules require these records to be kept for five years from the report's due date. Apps make this harder than banks do: export statements while you still have access, since a closed app account can take its history with it.

An account maintained at a foreign financial institution abroad can also be within Form 8938 scope. Form 8938 is attached to the applicable tax return and has separate thresholds and ownership rules; pure signature authority is treated differently from FBAR.

Account location and the maintaining institution matter: a foreign branch of a US financial institution is generally within FBAR scope but not reported as that account on Form 8938. A US branch of a foreign financial institution is outside both account-reporting categories. Other assets and accounts must still be tested.

Establish whether a report was required, whether a previous report needs correction and whether related income or returns were omitted. These facts lead to different correction and catch-up questions.

Streamlined procedures require additional residency and non-willfulness conditions. A missed account does not automatically establish eligibility or penalty relief. Get individual advice if conduct, an examination or penalties are in question.