FBAR & FinCEN 114 for Americans Abroad

FBAR filing, handled end to end.

If you're an American in Italy with a bank account, a Postepay card, or a brokerage account, the FBAR is probably the form you owe and didn't know about. We prepare it, file it, and clean up late years through the IRS Streamlined Procedure — penalty-free where you qualify.

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The FBAR catches more Americans abroad than the 1040 ever does.

An FBAR — the Foreign Bank Account Report, technically FinCEN Form 114 — is required of any U.S. citizen or green card holder whose foreign financial accounts, added together, exceeded $10,000 at any point during the year. It is not part of your tax return. It is filed separately, through the Treasury Department's anti-money-laundering system, on its own deadline. That separation is exactly why so many Americans in Italy miss it for years without realizing.

The threshold is an aggregate, not a per-account number. Three accounts holding $4,000 each clears it. The accounts that trip people up are the ones they don't think of as "investment" accounts: a Postepay card with a balance, a joint account held with an Italian spouse, a business account where you're only a signatory, cash-value life insurance, certain Italian pension accounts. We inventory every account, decide what's reportable, and file it correctly.

The penalty regime is what makes this matter. Non-willful violations run up to roughly $10,000 each; willful ones scale to half the account balance. But the IRS built a path specifically for honest late filers, and using it correctly is almost always penalty-free. For the full mechanics, see our guide to reporting Italian bank accounts to the IRS.

FBAR filing for Americans with Italian bank accounts — FinCEN Form 114 — Italian bank, brokerage, and Postepay balances are all reportable on the FBAR once your accounts clear $10,000 in aggregate.

What's included

Every reportable account, found and filed — current year and back years.

Current-year FBAR preparation

FinCEN Form 114 prepared and e-filed for every foreign account above the $10,000 aggregate threshold, with maximum-balance figures converted at the correct Treasury year-end rate.

Form 8938 / FATCA reporting

The IRS counterpart to the FBAR, filed with your 1040 when your balances clear the higher 8938 thresholds. We file both correctly — one does not replace the other.

Account inventory & signature-authority review

We work through every account systematically — personal, joint, business signature-only, Postepay, life insurance, pensions — so nothing reportable is left off and nothing non-reportable is over-disclosed.

Streamlined catch-up for late filers

Haven't filed in years? The Streamlined Foreign Offshore Procedure covers six years of back FBARs and three years of returns with a non-willful certification — typically penalty-free if you qualify.

Late or never filed?

Late FBAR penalties are steep — and almost always avoidable.

The single most common situation we see: an American who has lived in Italy for years, files (or doesn't file) a U.S. return, and has never heard of the FBAR. The fear when they find out is the penalty — and the penalties on paper are genuinely severe. The reality for honest non-filers is far less frightening.

If the failure to file was non-willful — you didn't know, which describes the overwhelming majority of people — the Streamlined Foreign Offshore Procedure is built for you. It brings you fully current with six years of back FBARs and three years of returns, paired with a non-willful certification. Penalties are typically waived entirely. The real risk is not filing late through the program; it's doing nothing and getting a FinCEN notice years later, when the cheap fix is no longer on the table.

The IRS publishes the FBAR requirement and the Streamlined terms directly. We work from the source: see the IRS FBAR reference and the FinCEN BSA E-Filing system where the form is actually lodged. Then we handle it for you.

How we work

Inventory, classify, file — and defend if needed.

Consultation & account list

A short call to learn your situation and how many years are open. We give you secure portal access and a checklist of every account type to gather.

Inventory & classify

We identify which accounts are reportable, pull maximum balances, and convert them at the correct year-end rate. We flag whether Form 8938 applies too.

File current & back years

Current-year FinCEN 114 e-filed. If you're behind, we assemble the full Streamlined package — back FBARs, returns, and non-willful certification.

Defend & keep you current

If a FinCEN or IRS question comes, we handle it. Going forward, your FBAR is filed alongside your annual return so it never lapses again.

Common questions

Questions we hear about the FBAR.

Who has to file an FBAR?

Any U.S. citizen, green card holder, or U.S. tax resident files an FBAR (FinCEN Form 114) if the aggregate value of all their foreign financial accounts exceeded $10,000 at any point during the calendar year. "Aggregate" means added together — three accounts at $4,000 each triggers it. The $10,000 is not a per-account threshold.

What is the penalty for filing an FBAR late?

Non-willful violations carry penalties up to roughly $10,000 per violation (adjusted for inflation), and willful violations can reach the greater of $100,000 or 50% of the account balance. But most late filers qualify for the Streamlined Foreign Offshore Procedure, under which penalties are typically waived entirely for non-willful non-filers. Filing late through the right program is almost always far cheaper than waiting for a notice.

I haven't filed FBARs in years. What do I do?

If the failure was non-willful — which is the case for most Americans abroad who simply didn't know — the IRS Streamlined Foreign Offshore Procedure is designed for exactly this. It requires six years of back FBARs, three years of returns, and a non-willful certification, and penalties are typically waived if you qualify. It's a structured catch-up, not a panic.

What's the difference between the FBAR and Form 8938?

The FBAR (FinCEN 114) goes to the Treasury's financial-crimes unit and is triggered at a $10,000 aggregate. Form 8938 goes to the IRS with your 1040 and has higher thresholds that depend on filing status and whether you live abroad. Many Americans in Italy file both — separate forms, separate rules, and one does not replace the other.

Which Italian accounts count toward the FBAR?

Bank accounts, Postepay cards with a balance, Italian brokerage accounts, joint accounts held with an Italian spouse, business accounts where you're a signatory but not an owner, cash-value life insurance with an Italian carrier, and certain Italian pension accounts can all count. The accounts people miss are usually the ones they don't think of as theirs — which is why we inventory every account. See our full FBAR guide.

When is the FBAR due?

The FBAR is due April 15, with an automatic extension to October 15 — no extension form required. It's filed electronically through the FinCEN BSA E-Filing system, separately from your federal tax return.