United States – FBAR Deadline Extended for Certain Individuals with Signature Authority

US – FBAR Deadline Extended for Certain Individuals

A new Notice issued by the U.S. Financial Crimes Enforcement Network further extends the FBAR filing deadline to April 22, 2022, for certain employees or officers who may have had to prepare an FBAR for the April 15, 2021 due date.


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The U.S. Financial Crimes Enforcement Network (FinCEN) announced a further extension of time for certain Foreign Bank and Financial Accounts (FinCEN Form 114, the “FBAR”) filings.1


This extension may provide welcome relief for certain employees or officers who may have had to prepare an FBAR for the April 15, 2021 due date.  This extension should relieve them of this obligation in 2021 and provide them with additional time to organize their affairs and take the steps – with plenty of lead time – to be compliant.   


On March 10, 2016, FinCEN issued a notice of proposed rule-making (NPRM) which proposes to revise the regulations implementing the Bank Secrecy Act regarding FBARs.  The proposed amendments would expand and clarify the exemptions for certain U.S. persons with signature or other authority over foreign financial accounts.

On December 20, 2019, FinCEN issued Notice 2019-1 to extend the filing date to April 15, 2021 for individuals (e.g., employees and officers of specified regulated entities) with signature authority over but no financial interest in one or more foreign financial accounts.2

FinCEN Notice 2020-1

The current Notice further extends the filing deadline to April 22, 2022.  The Notice covers those individuals whose

filing due date was previously extended by FinCEN Notice 2019-1; however, for all other individuals with an FBAR filing obligation, the filing due date remains April 15, 2021.


The extension is for FinCEN to address and further consider the exemptions in the NPRM from March 2016 – yet to be finalized – which revises application of the filing requirement to similarly-situated individuals.3


1  See FinCEN Notice 2020-1.

2  Id.  For prior coverage, see GMS Flash Alert 2020-003, January 6, 2020.

3  Id.

The above information is not intended to be "written advice concerning one or more Federal tax matters" subject to the requirements of section 10.37(a)(2) of Treasury Department Circular 230 as the content of this document is issued for general informational purposes only.


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