Revolut, the FBAR, and the hidden fund inside 'Flexible' accounts

Revolut feels like an app, not a bank — which is exactly why it's one of the most under-reported accounts on FBARs. For a US person there are two separate issues: the balance itself, and what the yield products actually are.

Issue 1 — the balance counts toward the FBAR

A Revolut account held with a non-US Revolut entity (Lithuania for the EEA, the UK for the UK) is a foreign financial account. Every currency balance and pocket counts toward the $10,000 FBAR aggregate at its maximum value during the year — even if it only crossed for a day, even if it's just your salary passing through. It also counts toward Form 8938. (US-resident customers of Revolut's US entity are a different case — the FBAR is about non-US accounts.)

Issue 2 — 'Flexible' accounts are funds, and funds are PFICs

Revolut's interest-style products in Europe (marketed as Flexible Cash Funds / savings-like features) generally work by placing your money in money-market funds domiciled outside the US. For a US taxpayer a non-US money-market fund is generally a PFIC — Form 8621 territory — even though the app presents it as a savings balance. The same look-through applies to UCITS ETFs bought through Revolut's trading tab.

What to export

• Every currency's maximum balance during the year (statements per currency).
• The fund name and ISIN behind any Flexible/savings product — it's in the product documents.
• Trading-tab positions with ISINs and year-end values.