Is each currency in a UK private bank multi-currency account a separate FBAR account?

FinCEN's guidance does not address currency balances under one relationship directly. The FBAR asks for the account number the bank uses, so where the bank issues a separate number or IBAN for each currency, we list each balance as its own account. Where the bank genuinely runs one account under one number, a single entry is defensible if valued conservatively. Apply the same approach every year and on Form 8938.

Which exchange rate converts a missed FBAR balance held in pounds, euros or Swiss francs?

Use the US Treasury Reporting Rates of Exchange for 31 December of the year being reported, published by the Bureau of the Fiscal Service. Find each account's peak in its own currency, then convert it at that year-end rate, not the rate on the day of the peak or the day you file. If no Treasury rate exists for a currency, FinCEN allows another verifiable rate provided you state its source.

Do I report a Lombard or securities-backed credit line on the FBAR?

The FBAR definitions centre on deposits, securities and cash-value policies, and the official FinCEN and IRS sources we reviewed do not list a borrowing facility as a reportable account. The pledged custody portfolio is reported at its full maximum value, without netting the loan. If the facility account ever held a credit balance, it behaved like a deposit account, and we treat it as reportable for that year.

Will HMRC tell the IRS about my UK private bank accounts?

UK financial institutions must review their accounts and report certain account holders to HMRC every year under the automatic exchange regime, which includes FATCA. UK banks collect US citizenship information for this purpose, and HMRC exchanges FATCA data with the IRS. The IRS may therefore already hold year-end information about your relationship that your own filings do not show, which is a strong reason to correct a missed FBAR promptly.

My spouse is British and not a US person. How do we report our joint account?

You report the joint account in Part III of your FBAR at its entire maximum value, not your half, and give the number of joint owners and your spouse's details. Your spouse has no FBAR obligation, so the Form 114a joint filing option does not apply. On the UK side, HMRC still taxes each spouse only on their own share of the interest and gains.

Can I still use the Delinquent FBAR Submission Procedures for a missed FBAR?

No. The IRS withdrew its Delinquent FBAR Submission Procedures page around 1 July 2026. Late FBARs are now filed through FinCEN's BSA E-Filing System with a reason for late filing and a reasonable-cause explanation where your returns were correct, or under the Streamlined Filing Compliance Procedures, entering 'Streamlined Filing Compliance Procedures' as the reason, where the returns also need correcting.

Missed FBAR: UK Private Bank Multi-Currency Accounts

A missed FBAR on a UK multi-currency account is corrected by identifying every reportable account inside the private-bank relationship, valuing each one at its highest balance in its own currency, converting that figure to US dollars at the Treasury Reporting Rate of Exchange for 31 December of the year concerned, and filing a late FinCEN Form 114 through the BSA E-Filing System with a reason for late filing. If your US returns also left out the deposit interest, dividends or gains that the relationship produced, the Streamlined Filing Compliance Procedures are normally the cleaner route, because they fix the returns and the FBARs together. The difficult part is rarely the filing itself. It is working out what counts as an account when one relationship manager, one online login and one consolidated statement cover pound, dollar, euro and Swiss franc balances, fixed-term deposits, a custody portfolio and sometimes a Lombard credit line.

In the returns we prepare for UK-resident Americans with private-banking relationships, the failure mode we see most often is not ignorance of the FBAR. It is the belief that the bank is one account. The client either files nothing because the relationship feels like a single line held in London, or files an FBAR that shows only the sterling current account and leaves out the currency balances, the deposits and the portfolio. The FBAR does not ask about relationships. It asks, account by account, for the maximum value during the year (Item 15), the type of account (Item 16: Bank, Securities or Other), the name of the financial institution (Item 17), the account number or other designation the institution uses (Item 18) and the institution's address (Items 19 to 23). FinCEN sets this out in its line item filing instructions at https://www.fincen.gov/sites/default/files/shared/FBAR%20Line%20Item%20Filing%20Instructions.pdf, and the rest of this guide maps a typical private-bank relationship onto those items.

What is a missed FBAR on a UK private bank relationship?

A missed FBAR is a Report of Foreign Bank and Financial Accounts (FinCEN Form 114) that was required for a calendar year but was not filed by the extended deadline. The IRS explains at https://www.irs.gov/businesses/small-businesses-self-employed/report-of-foreign-bank-and-financial-accounts-fbar that a US person must file when they have a financial interest in, or signature authority over, foreign financial accounts whose aggregate value exceeded $10,000 at any time during the calendar year. The report is due on 15 April following the year, with an automatic extension to 15 October, and it must be filed electronically through FinCEN's BSA E-Filing System.

Two points trip up private-bank clients. First, whether an account is foreign depends on where it is maintained, not on its currency. FinCEN's instructions say that an account with a branch of a US bank physically located outside the United States is a foreign financial account, so a US dollar balance held with a London private bank is foreign even though it never leaves dollars. Second, the $10,000 test is an aggregate of the maximum values of every account. Once it is crossed, every account must be listed, including small ones. IRS Publication 5569 at https://www.irs.gov/pub/irs-pdf/p5569.pdf gives the example of a filer with accounts worth $100, $12,000 and $3,000 who must report all three.

Is each currency balance in a multi-currency account a separate FBAR account?

FinCEN's definition of a financial account is broad. Its instructions describe it as including, but not limited to, a securities, brokerage, savings, demand, checking, deposit, time deposit or other account maintained with a financial institution. What FinCEN does not do is say whether the separate currency balances held under one private-bank relationship are one account or several. We checked the FBAR line item instructions, the 2011 final rule that rewrote the FBAR regulations, and the IRS examiner guidance in IRM 4.26.16 at https://www.irs.gov/irm/part4/irm_04-026-016. None of them addresses currency pockets directly, and we would be wary of any page that claims a definitive official answer.

The practical anchor is Item 18, which asks for the account number the financial institution uses to designate the account. Private banks structure this in different ways. Some open a separate account, with its own number or IBAN, for every currency the client holds. Others run one multi-currency account under a single number and show the currency balances as sub-ledgers. The conservative, consistent approach we apply is:

Where the bank issues a separate account number or IBAN for each currency balance, list each balance as its own account with its own maximum value, type Bank.
Where the bank genuinely designates one account under a single number, one entry is defensible, but value it conservatively as explained below and keep a note in your file of every currency held within it.
Fixed-term and fiduciary deposits that carry their own deposit number are listed separately as Bank accounts; deposits booked inside the current account under the same number are captured in that account's value.
The custody or investment portfolio is a separate securities account, type Securities, whatever mix of currencies its holdings are denominated in.
Whatever structure you adopt, apply it identically for every year filed and mirror it on Form 8938.

The reason to lean towards more entries rather than fewer is that the penalty rules turn on accurate account-level reporting. The FBAR instructions say that no penalty is imposed where there is reasonable cause for the failure and the balance in the account is properly reported, and that exception, written into 31 U.S.C. 5321(a)(5)(B)(ii), applies only where the balance in the account was properly reported. Listing a currency balance separately when one entry would have sufficed costs nothing. Folding a separately numbered balance into another entry, or leaving it out, is the error. If itemising a large relationship takes you to 25 or more accounts, the abbreviated reporting option in Item 14 may apply, which we cover in a separate guide; records of every account must still be kept and produced if FinCEN or the IRS asks.

How do you value a multi-currency account for a missed FBAR?

FinCEN's two-step method, set out at https://www.fincen.gov/reporting-maximum-account-value, is the starting point. Step one is to determine the maximum value of each account, in the currency of that account, during the calendar year. The maximum value is a reasonable approximation of the greatest value of currency or non-monetary assets in the account, and periodic statements may be relied on if they fairly reflect that maximum; IRS Publication 5569 refers to statements issued at least quarterly. Step two is to convert that maximum into US dollars using the Treasury rate for the last day of the calendar year. If no Treasury rate is available, you use another verifiable rate and give its source. Values are recorded in whole dollars, rounded up, and a negative result is entered as zero.

The Treasury Reporting Rates of Exchange are published quarterly by the Bureau of the Fiscal Service in the dataset at https://fiscaldata.treasury.gov/datasets/treasury-reporting-rates-exchange/treasury-reporting-rates-of-exchange, and they are quoted as units of foreign currency per US dollar. You therefore divide a sterling, euro or Swiss franc maximum by the 31 December rate for that currency to reach dollars. Use the 31 December rate for the year being reported, not the rate on the day the balance peaked and not the rate on the day you file.

Step one assumes each account has one currency. A single-number multi-currency account does not, so the instruction cannot be applied literally. The approach we use is to find the peak of each currency balance in its own currency, convert each peak at its own 31 December rate, and add the results. Because the balances rarely peak on the same day, the total is at least as high as the true maximum combined balance, and usually higher. The alternative, taking the highest combined value shown on any single statement, is defensible only where the statements are frequent enough to capture the peaks. When money moves between pockets, for example sterling converted into dollars to fund a purchase, summing peaks can count the same money twice. That overstatement is the safer error: the FBAR reports account values, not income, and a higher value creates no tax.

A custody portfolio is simpler than it looks. The bank values the whole portfolio in a reference currency, typically sterling for a UK relationship, even when the holdings include US, euro and Swiss securities. Take the highest portfolio valuation in that reference currency during the year, convert it at the 31 December rate, and report it as one securities account. Do not split it into currency components. If the only statements are quarterly and markets peaked between them, a monthly valuation from the bank is worth requesting, because the figure must fairly reflect the maximum.

Worked illustration: one relationship, six FBAR entries

The figures below are an illustration only. Assume a UK-resident American with one private-bank relationship booked in London for calendar year 2025, where the bank issues a separate account number for each currency balance, a separate reference for a sterling fixed-term deposit, and a separate number for the custody portfolio. Assume, purely for the arithmetic, 31 December Treasury rates of 0.80 pounds, 0.90 euros and 0.85 Swiss francs per US dollar. These are not the published rates; the real figures must be taken from the Treasury dataset for the year being reported.

Sterling current account: peak balance of £180,000 in March after a bonus. 180,000 divided by 0.80 gives $225,000. Type Bank.
US dollar account: peak balance of $95,000 in April. No conversion is needed. Type Bank.
Euro account: peak balance of €60,000 in July. 60,000 divided by 0.90 gives $66,666.67, entered as $66,667. Type Bank.
Swiss franc account: peak balance of CHF 40,000 in October. 40,000 divided by 0.85 gives $47,058.82, entered as $47,059. Type Bank.
Six-month sterling fixed-term deposit of £500,000 that matured in September. 500,000 divided by 0.80 gives $625,000. Type Bank, reported for the year even though it matured.
Custody portfolio with a peak valuation of £2,400,000 in its sterling reference currency. 2,400,000 divided by 0.80 gives $3,000,000. Type Securities.

Six entries, each with the bank's full legal name, the account number or deposit reference, and the address of the office where the accounts are held, total $4,058,726. Two observations from files like this. First, the April dollar peak was funded by converting part of the March sterling bonus, so the two peaks partly count the same money; that is acceptable, because each figure is the genuine maximum of a separately numbered account. Second, if this bank had instead operated one multi-currency current account under a single number, the four currency lines would collapse into one entry of $433,726 using the sum-of-peaks method, with the deposit and the portfolio still listed separately. The relationship is reported either way. What changes is the number of lines, and that choice should follow how the bank itself designates the accounts.

Are custody portfolios, fixed deposits and Lombard credit lines reportable?

Custody portfolios are. The 2011 FBAR regulations treat a securities account, meaning an account with a person engaged in the business of buying, selling, holding or trading stock or other securities, as a financial account, and the FBAR instructions list securities and brokerage accounts expressly. Time deposits are also named in the definition, so fixed-term deposits are reportable bank accounts even if they were placed for a few weeks and matured within the year. Fiduciary deposits, where the bank places cash with other institutions on the client's behalf, are not specifically addressed in FinCEN guidance; we report them through the account at the private bank that holds and records them, using the designation the bank gives them.

A Lombard or securities-backed credit facility needs more care. The official definitions are framed around deposits, securities and policies with a cash value, and none of the FinCEN or IRS sources we reviewed lists a borrowing facility as a reportable account in its own right. A loan account in debit would in any case produce a negative value, and FinCEN tells filers to enter zero where the value is negative. Three practical rules follow:

Report the pledged custody portfolio at its full maximum value. The loan secured on it is not netted against it, because the FBAR measures the value of the assets in the account.
Where loan proceeds are paid into a currency account, they form part of that account's balance and its maximum value.
If the facility account ever carried a credit balance, for example after an overpayment or a drawdown left parked in it, it behaved like a deposit account for that period, and we treat it as reportable for that year.

Form 8938 reaches the same place by a different road. Its instructions say that a specified foreign financial asset with a value below zero is reported at zero, so liabilities never reduce the figures you report on either form.

How does Form 8938 treat the same private bank relationship?

Form 8938 is the IRS's own foreign asset statement, filed with the income tax return, and it overlaps heavily with the FBAR. The IRS comparison at https://www.irs.gov/businesses/comparison-of-form-8938-and-fbar-requirements confirms that both forms cover financial (deposit and custodial) accounts held at foreign financial institutions, and that filing Form 8938 does not relieve you of the FBAR. For taxpayers living abroad, the Form 8938 threshold is met when specified foreign financial assets exceed $200,000 on the last day of the tax year or $300,000 at any time for a single filer, and $400,000 or $600,000 respectively for married couples filing jointly. A relationship like the one illustrated above clears those thresholds easily.

The Form 8938 instructions at https://www.irs.gov/instructions/i8938 use the exchange rate on the last day of the tax year, taken from the Treasury rates where available, and require you to disclose any other publicly available rate you use. For a calendar-year individual this produces the same conversion as the FBAR. That makes consistency checks practical, and IRS reviewers can run them too. Before filing, we reconcile the two forms line by line:

The same accounts appear on both, with the same account numbers or deposit references.
Maximum values match, allowing only for the FBAR's rounding up to the next whole dollar.
The same exchange rate and source are used for each currency.
Deposits that matured and accounts opened during the year are flagged consistently.
Interest, dividends and gains shown against each account on Form 8938 agree with the amounts reported on the return.
Joint accounts are handled under each form's own rules, which are not identical.

A single-number multi-currency account listed once on the FBAR but as four accounts on Form 8938, or valued differently on each, is exactly the kind of inconsistency that invites questions. Pick one map of the relationship and use it on both.

How does the bank's FATCA and CRS reporting make the gap visible?

A UK private bank is not a passive record-keeper. GOV.UK guidance at https://www.gov.uk/guidance/automatic-exchange-of-information-financial-institutions tells financial institutions that they must review the accounts they maintain and report certain account holders to HMRC every year, and it confirms that the automatic exchange regime includes FATCA as well as the Common Reporting Standard. UK institutions must collect information on the residence of their account holders and, for the United States, citizenship as well, which is why private banks ask American clients for a self-certification. HMRC's reporting guidance at https://www.gov.uk/guidance/how-to-report-automatic-exchange-of-information sets the filing date for each year ending 31 December as the following 31 May, and notes that from 1 January 2027 FATCA and CRS returns will be made separately rather than on a combined schema.

The information HMRC receives under FATCA exists so that it can be exchanged with the IRS under the UK and US intergovernmental agreement. The practical consequence is that the IRS may already hold year-end information about your relationship, reported by the bank, that none of your own filings reflect. Relationships booked through offices in Jersey, Guernsey, the Isle of Man or Switzerland are reported under those jurisdictions' own arrangements, with the same end result. We treat bank reporting as a reason to act early, because the IRS guidance on late FBARs is framed around taxpayers the IRS has not contacted and who are not under investigation.

What records should you request from your private bank?

Private banks can produce everything a missed FBAR needs, but only if you ask precisely. Relationship managers tend to send the consolidated wealth report, which is designed for investment reviews rather than reporting. For each year you are filing, which is six years of FBARs under the Streamlined Foreign Offshore Procedures, request:

A list of every account, sub-account, deposit and portfolio number that existed at any point in the year, including closed and matured items, with the currency of each.
Monthly, or at least quarterly, statements for each currency account, so the peak in each currency can be identified.
Placement and maturity confirmations for every fixed-term and fiduciary deposit, showing the amount, the dates and the reference used.
Monthly valuation statements for the custody portfolio in its reference currency, and the date of the highest valuation.
The credit facility agreement and loan account statements, to confirm whether the facility ever carried a credit balance.
The full legal name and address of the entity and office where each account is held, which matters when the relationship manager sits in London but the accounts are booked elsewhere.
Confirmation of the account holders and any joint owners recorded on each account.

FinCEN requires filers to keep records of the name on each account, the account number, the institution's name and address, the type of account and the maximum value, for five years from 15 April of the year after the year reported, or from the filing date if later. Keep the bank's letters with your copy of each filed report.

How do you report a joint account with a non-US spouse?

Many UK-resident Americans hold the private-bank relationship jointly with a British spouse who is not a US person. The IRS guidance at https://www.irs.gov/newsroom/details-on-reporting-foreign-bank-and-financial-accounts is direct: where two people jointly own a foreign financial account, each has a financial interest and each person required to file must report the entire value of the account, not their share. You report joint accounts in Part III of the FBAR, giving the number of joint owners and the principal joint owner's name and address, and their taxpayer identification number if known.

The option for spouses to file a single joint FBAR using Form 114a is designed for couples where both spouses have a filing obligation. A spouse who is not a US person has no FBAR obligation of their own, so the American spouse files alone and reports the full value. On Form 8938, the instructions say that where you jointly own an asset with a spouse who is not a specified person, each joint owner includes the entire value of the asset in determining whether the reporting threshold is met. On the UK side nothing changes: HMRC taxes each spouse on their own share of the interest and gains, and the full-value rule is purely a US reporting convention.

How do you fix a missed FBAR: late filing or the Streamlined procedures?

The right route depends on whether your US tax returns were correct. If you filed complete returns that reported all the interest, dividends and gains from the relationship, and only the FBARs are missing, the IRS says that where it has not contacted you about a late FBAR and you are not under civil or criminal investigation, you should file the late FBARs as soon as possible. They are filed through the BSA E-Filing System, one report for each missed year. When a report is filed after the 15 October extended deadline, the system asks for the reason for late filing from a drop-down list, and IRS Publication 5569 explains that you can select Other and use a text box of up to 750 characters to explain the late filing or to indicate that it is made in conjunction with an IRS compliance option. The publication also says that if the account is properly reported on a late FBAR and the IRS determines the violation was due to reasonable cause, no penalty will be imposed.

Be careful with older articles. The IRS withdrew its Delinquent FBAR Submission Procedures page around 1 July 2026, and when we checked on 10 September 2026 the former address returned a not found error. There is no longer a published IRS page offering that route, so a late FBAR filed on its own now rests on a clear, factual reasonable-cause explanation in the late-filing text box.

If the returns were also wrong, which is common when deposit interest in four currencies, portfolio income and currency gains were never reported in the US, the Streamlined Filing Compliance Procedures at https://www.irs.gov/individuals/international-taxpayers/streamlined-filing-compliance-procedures are usually the better fit. They require you to certify that the failures were due to non-willful conduct, which the IRS defines as conduct due to negligence, inadvertence or mistake, or a good faith misunderstanding of the requirements of the law. For Americans living in the UK, the Streamlined Foreign Offshore Procedures at https://www.irs.gov/individuals/international-taxpayers/us-taxpayers-residing-outside-the-united-states require:

Meeting the non-residency test: no US abode and physically outside the United States for at least 330 full days in any one of the three most recent years for which the return due date has passed.
Three years of delinquent or amended returns on Form 1040 or Form 1040-X, including a complete Form 8938 built from the same map of the relationship.
Six years of delinquent FBARs filed through the BSA E-Filing System, selecting Other as the reason for late filing and entering 'Streamlined Filing Compliance Procedures' in the explanation box.
A signed Form 14653 certifying eligibility and non-willful conduct, with a narrative explaining how the failure happened.

Taxpayers who comply with the foreign offshore procedures are not subject to failure-to-file and failure-to-pay penalties, accuracy-related penalties, information return penalties or FBAR penalties. A separate domestic version exists for US residents on different terms. If the facts suggest the accounts were deliberately concealed, neither route is appropriate and the case needs specialist handling before anything is filed.

Missed FBAR penalties after Bittner

The FBAR instructions set the civil penalty for a non-willful failure at up to $10,000 per violation, and IRS Publication 5569 notes that the upper limits are adjusted annually for inflation, so check the current figure rather than relying on the statutory amount. In Bittner v. United States, decided on 28 February 2023 (opinion at https://www.supremecourt.gov/opinions/22pdf/21-1195_h3ci.pdf), the Supreme Court held that the maximum non-willful penalty accrues per report, not per account. For a private-bank client that matters: six entries on one late report expose one report, not six. Willful penalties can still be measured per account, at up to the greater of $100,000 (as adjusted) or 50 percent of the balance at the time of the violation, and the reasonable cause exception still depends on every account being properly reported.

Your next steps

Ask the bank for the account list, statements and deposit confirmations described above for every year you need to file.
Build one map of the relationship: which items carry their own number, and which sit inside another account.
Value each item at its peak in its own currency and convert at the Treasury 31 December rate for each year.
Check whether your US returns picked up the interest, dividends and currency gains, and reconcile everything to Form 8938.
Choose late FBARs alone or the Streamlined Foreign Offshore Procedures, then file every year on the same basis.

Our team prepares late FBARs, amended returns and Streamlined submissions for UK-resident Americans with private-banking relationships, from the first request to the bank through to the filed reports. If your relationship holds more balances than your past filings show, start with the account map; everything else follows from it.