Does a foreign cryptocurrency exchange account require FBAR reporting for U.S. expats?

FinCEN Notice 2020-2 indicates that foreign cryptocurrency exchange accounts will be subject to FBAR reporting once the final rule is issued. While the regulation is not yet finalized, most tax practitioners recommend that U.S. expats report foreign-custodied crypto accounts on the FBAR now. Expats face additional complexity because living abroad often means your primary exchange is a foreign platform, creating FATCA and Form 8938 obligations in addition to the FBAR question.

• Conservative FBAR filing: Report any account on a foreign centralized exchange (Binance non-U.S., Bitstamp, Kraken EU, Crypto.com Singapore, OKX) as a foreign financial account
• Self-custody wallets: Hardware wallets and software wallets you control are not held at a financial institution, so they are likely outside the FBAR scope
• DeFi protocols: No custodian holds your funds, so FBAR likely does not apply, but guidance is still evolving
• Hybrid platforms: Some exchanges also offer staking, lending, or savings products that create additional taxable events

Why expats face extra crypto reporting layers:

Expat-specific considerations:

Local exchange regulations vary. Some countries (Japan, South Korea) require identity verification that ties your account to a local address, making the account clearly foreign for FBAR purposes. Others (UAE, Portugal) have lighter reporting, but do not change your U.S. obligations.

If you used a U.S.-based exchange before moving abroad and kept the account open, that account is not considered a foreign account for FBAR purposes, even if you access it from overseas. Only accounts maintained by a non-U.S. entity qualify.

For crypto reporting help, see our Cryptocurrency Tax Guide.