Do I need to report a Revolut or Wise account on my FBAR?

In practice, yes, if the account is maintained outside the United States and your foreign accounts together exceeded $10,000 at any time in the year. The FBAR regulation does not expressly mention e-money, but IRS Publication 5569 describes financial accounts broadly as accounts with a person performing the services of a financial institution. Reporting the account costs nothing, while omitting it can create penalty exposure, so we report these accounts in the returns we prepare.

Is a UK e-money account protected by the FSCS like a bank deposit?

Generally no. The FSCS states that it cannot protect money held with e-money institutions and payment providers. Instead, the FCA requires those firms to safeguard customer funds by segregating them or protecting them with insurance, so money can be returned if the firm fails. Some apps place savings with partner banks that do have FSCS cover. This UK distinction does not remove the US FBAR obligation for the account.

How do I convert sterling and euro balances for the FBAR?

Find the maximum balance in each currency during the calendar year, then convert it to US dollars using the US Treasury Reporting Rates of Exchange for the last day of that calendar year, published on fiscaldata.treasury.gov. If no Treasury rate exists for a currency, use another verifiable rate and state its source. Do not use the exchange rate on the date of the peak balance, and do not use HMRC average rates.

How do I file a late FBAR for a missed e-money account?

File the missing FinCEN Form 114 reports electronically through FinCEN's BSA E-Filing System, selecting the past calendar year for each. The form lets you explain the late filing, or select Other and enter up to 750 characters. If your US returns were otherwise correct and the IRS finds reasonable cause, no penalty is imposed. The IRS withdrew its separate Delinquent FBAR Submission Procedures page in 2026, so file through BSA E-Filing directly.

Should I use the Streamlined Foreign Offshore Procedures instead?

Use Streamlined Foreign Offshore if your US tax returns were also wrong, for example unreported interest, consulting income or fund holdings connected to the account, and your failure was non-willful. You must meet the non-residency test, file three years of returns and six years of FBARs, certify on Form 14653 and pay tax and interest. Eligible filers are not subject to FBAR or information return penalties.

Does filing Form 8938 cover my e-money account instead of the FBAR?

No. The IRS states that the Form 8938 requirement does not replace or otherwise affect the obligation to file FinCEN Form 114. Form 8938 is filed with your tax return and, for taxpayers living abroad, applies above higher thresholds, such as more than $200,000 at year end or $300,000 at any time for single filers. Many UK-resident clients must report the same e-money account on both forms.

Missed FBAR on Revolut and Wise Accounts: UK Guide

Missed FBAR on Revolut and Wise Accounts is one of the most common compliance gaps we find when a US person living in the UK first asks us to review their filings. The short answer: treat a UK multi-currency e-money account as a reportable foreign financial account, include its highest balance in your aggregate figure, and if you left it off, file the missing FinCEN Form 114 reports through FinCEN's BSA E-Filing System with a reason for filing late. If your US tax returns are also wrong, the Streamlined Foreign Offshore Procedures are usually the better route.

Why the confusion? These accounts do not look like a traditional bank account. They are often held with an electronic money institution rather than a bank, they are run from an app, and they split balances across currency pockets. Many clients assume that only high-street bank accounts count. This guide explains what the regulation actually says, where the position is not expressly addressed, why we report conservatively in the returns we prepare, and exactly how to put missed years right.

What is an FBAR and who has to file it?

The FBAR is FinCEN Form 114, the Report of Foreign Bank and Financial Accounts. 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 if they have a financial interest in, or signature or other authority over, at least one financial account located outside the United States, and the aggregate value of those foreign accounts exceeded $10,000 at any time during the calendar year. US citizens remain US persons wherever they live, so a US citizen resident in London is fully in scope.

The report is due April 15 following the calendar year, with an automatic extension to October 15 that does not need to be requested. It is filed electronically with FinCEN, not attached to Form 1040. The IRS FBAR Reference Guide (Publication 5569, https://www.irs.gov/pub/irs-pdf/p5569.pdf) also confirms that tax treaties do not affect FBAR filing obligations, so electing UK treaty residence does not switch the FBAR off.

Is an e-money account a financial account under 31 CFR 1010.350?

This is the genuinely nuanced point, and most online guidance skips it. The governing regulation is 31 CFR 1010.350 (readable at https://www.law.cornell.edu/cfr/text/31/1010.350). Paragraph (c) sets out three categories of reportable account:

Bank account: a savings deposit, demand deposit, checking or any other account maintained with a person engaged in the business of banking.
Securities account: an account with a person engaged in the business of buying, selling, holding or trading stock or other securities.
Other financial account: an account with a person in the business of accepting deposits as a financial agency; a cash-value insurance or annuity policy; an account with a broker or dealer for commodity futures or options; and an account with a publicly offered pooled fund with regular net asset value determinations and redemptions.

An electronic money account is not a neat fit for any single limb. Under UK law, e-money is a distinct regulated product from a bank deposit. The Electronic Money Regulations 2011 (https://www.legislation.gov.uk/uksi/2011/99/contents) govern e-money issuers separately from deposit-takers, and an electronic money institution that does not hold a banking licence is not, in UK regulatory terms, taking deposits. Read literally, that makes it arguable that a pure e-money account is neither a deposit account with a bank nor an account with a person accepting deposits as a financial agency.

The regulation does not expressly address e-money, and we are not aware of FinCEN or IRS guidance that addresses UK e-money institutions by name. What the IRS does say points firmly the other way from a narrow reading. Publication 5569 describes financial accounts as including any other accounts maintained in a foreign financial institution or with a person performing the services of a financial institution. An app account that holds your money, issues you an account number or IBAN, and lets you receive, hold, convert and pay out funds is performing exactly those services.

Why practitioners report e-money accounts conservatively

In the returns we prepare, we report these accounts. The reasons are practical rather than theoretical:

Asymmetric risk: including an account that arguably was not reportable costs nothing, while omitting one that the IRS treats as reportable exposes you to FBAR penalties.
The IRS description of a financial account in Publication 5569 is broad and function-based, and an e-money account functions as a place where money is held for you.
The line is not always visible to the customer: some fintech providers hold banking licences in some jurisdictions, some sweep balances to partner banks, and the legal entity behind your account can change over time.
Pleading a technical e-money argument after the fact is a weak foundation for a reasonable cause or non-willful narrative; a complete filing is a much stronger one.
Form 8938 and the FBAR are tested separately, so an e-money account left off one form is often missing from the other as well.

One carve-out the IRS does spell out is virtual currency. Publication 5569 states that a foreign account holding only virtual currency is not currently reportable on the FBAR unless it also holds other reportable assets, while noting that FinCEN Notice 2020-2 signals an intention to propose extending the rule. If your app account holds fiat currency pockets as well as crypto, the account holds reportable assets and should be treated as reportable.

Is the account foreign? Location, not currency, decides

Publication 5569 is explicit that it is the location of the account, not the nationality of the institution, that makes it foreign. A US dollar pocket inside a UK-maintained e-money account is still a foreign account, because the account is maintained outside the United States. Equally, some fintech groups offer accounts through US entities; an account genuinely maintained in the United States is not foreign. The failure mode we see most often is a client assuming their US dollar balance is domestic because it has US bank details attached for receiving payments. Check your account terms to see which legal entity, and which country, maintains the account.

UK e-money safeguarding is not FSCS deposit protection

The UK protection regime is worth understanding, both because clients raise it and because it illustrates why these accounts are legally different from deposits. The FCA explains at https://www.fca.org.uk/firms/emi-payment-institutions-safeguarding-requirements that payment and e-money institutions must safeguard customer funds, meaning they segregate those funds from their own money or protect them with insurance or a comparable guarantee, so the funds can be returned if the firm fails. The FCA is clear that this is not FSCS protection. Updated safeguarding rules took effect in May 2026, tightening reconciliation, audit and resolution planning requirements.

The Financial Services Compensation Scheme states at https://www.fscs.org.uk/news/protection/e-money-and-fscs-protection/ that it cannot protect money held with e-money institutions and payment providers, although some apps let customers hold money with partner banks that do carry FSCS protection. None of this changes the US analysis: FSCS coverage is irrelevant to whether an account is reportable. But it does mean you should know whether any balance sits in a separate partner-bank account, because that can be a second reportable account in its own right.

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

The FBAR asks for the maximum value of each account. Publication 5569 defines maximum value as a reasonable approximation of the greatest value of currency and non-monetary assets in the account during the calendar year. You may rely on periodic statements issued at least quarterly if they fairly reflect the maximum value. The method is: determine the maximum in the currency of the account, then convert to US dollars using the Treasury Reporting Rates of Exchange for the last day of the calendar year. If no Treasury rate is available, use another verifiable rate and state its source. Treasury publishes the rates at https://fiscaldata.treasury.gov/datasets/treasury-reporting-rates-exchange/.

Multi-currency pockets raise a question the guidance does not directly answer: is one app account with sterling, euro and dollar pockets one account in several currencies, or several accounts? Our working method is conservative and documented:

Export the full transaction history for the year, not just a year-end statement, because quarterly statements often miss a mid-quarter peak such as a bonus or property completion passing through.
Identify the highest balance in each currency pocket separately.
Convert each pocket's maximum at the Treasury year-end rate for that currency; US dollar pockets need no conversion.
Add the converted maxima together to produce the maximum value reported for the account. Because the peaks may fall on different days, this can overstate the true single-day maximum, which is the safe direction.
Where a pocket has its own distinct account number or IBAN, or sits with a partner bank, consider reporting it as a separate account.
Keep the workings: records must generally be retained for five years from the FBAR due date.

Remember the threshold is aggregate. Publication 5569 gives the example of three accounts with maximum values of $100, $12,000 and $3,000: the aggregate of $15,100 triggers filing and all three accounts must be reported, even the small ones. A dormant e-money account with a few pounds in it still goes on the form once you are over the aggregate threshold.

A worked scenario: the London banker with a travel card

Illustration only, using assumed figures and assumed exchange rates, not actual Treasury rates. Daniel is a US citizen working in investment banking in London. He files US returns every year and reports his UK current account and UK brokerage account on his FBAR. He also has a multi-currency e-money account he uses for travel and for receiving US dollar consulting fees. He has never reported it.

Reviewing the export, we find the sterling pocket peaked at 28,000 pounds when his bonus passed through before a transfer to his main bank, the euro pocket peaked at 6,000 euros before a ski trip, and the dollar pocket peaked at 9,000 dollars. Assuming a year-end Treasury rate of 0.80 pounds per dollar and 0.90 euros per dollar, the converted maxima are 35,000 dollars, about 6,667 dollars and 9,000 dollars, so the account is reported at a maximum value of about 50,667 dollars. His FBARs were filed, but incomplete.

Two further issues surface. The dollar consulting fees landed in the app and were never entered on his Form 1040, so his returns understated income. And for two years he held a savings feature inside the app that invested in a money market fund, which can be a passive foreign investment company requiring Form 8621. Because his returns, not just his FBARs, need correcting, the late-FBAR route alone would not resolve his position; we moved him into the Streamlined Foreign Offshore Procedures.

Missed FBAR on Revolut and Wise Accounts: how to fix it

The right route depends on one question: were your US tax returns correct apart from the missing FBAR disclosure? Note that the IRS withdrew its separate Delinquent FBAR Submission Procedures page around 1 July 2026, so it should not be treated as a live named programme. The routes now are late filing through BSA E-Filing, or the Streamlined Filing Compliance Procedures.

Route one, late FBARs only. If all income from the account was reported and tax paid, and you are not under IRS examination or criminal investigation, file the missing FBARs through the BSA E-Filing System at https://bsaefiling.fincen.treas.gov as soon as possible. The IRS FBAR page advises filing late FBARs promptly to keep potential penalties to a minimum. Publication 5569 explains that you can enter past calendar years on the online Form 114 and use the late-filing explanation, or select Other and enter up to 750 characters, to explain why the filing is late or that it is made in conjunction with an IRS compliance option. If the IRS determines the violation was due to reasonable cause, no penalty is imposed. A good explanation is factual and specific: for example, that the account was held with an e-money institution you understood was not a bank, that the balances were fully taxed and reported, and that you filed promptly on discovering the obligation.

Route two, Streamlined Foreign Offshore Procedures. If the account also carried unreported interest, fees, trading income or a fund holding, the returns are wrong too. The IRS page at https://www.irs.gov/individuals/international-taxpayers/us-taxpayers-residing-outside-the-united-states sets out the requirements:

Meet the non-residency test: for a US citizen or green card holder, no US abode and physically outside the United States for at least 330 full days in at least one of the three most recent tax years.
Certify on Form 14653, under penalties of perjury, that the failures resulted from non-willful conduct.
File three years of delinquent or amended returns, including required information returns such as Forms 8938, 5471 and 3520.
File six years of delinquent FBARs through BSA E-Filing.
Pay all tax and statutory interest due.

Eligible taxpayers are not subject to failure-to-file, failure-to-pay, accuracy-related, information return or FBAR penalties, unless the IRS later determines the conduct was fraudulent or willful. For UK-resident clients whose non-compliance is limited to overlooked fintech accounts, this is typically a clean resolution.

How Form 8938 overlaps with the FBAR for e-money accounts

Form 8938 is a separate IRS disclosure filed with your income tax return. The IRS comparison at https://www.irs.gov/businesses/comparison-of-form-8938-and-fbar-requirements confirms that Form 8938 does not replace the FBAR. For taxpayers living abroad, the Form 8938 threshold is more than $200,000 on the last day of the tax year or more than $300,000 at any time for single filers and married filing separately, and more than $400,000 or $600,000 respectively for married filing jointly. FBAR balances are converted at the end-of-year rate; Form 8938 uses fair market value in dollars under its own instructions.

In practice, high-net-worth UK residents often exceed both thresholds, so an omitted e-money account can mean an incomplete Form 8938 as well as an incomplete FBAR. Form 8938 penalties are separate, up to $10,000 for failure to disclose with further penalties for continued failure after IRS notice. Schedule B of Form 1040 also asks whether you had a financial interest in or signature authority over a foreign account, and an unchecked box there is a small but visible inconsistency.

Gap angles most guides miss

Business accounts and signature authority. Many UK business owners run a limited company's payments through a business e-money account. If you can authorise payments from that account, you may have signature or other authority requiring FBAR reporting even though the money is the company's. If the company is a foreign corporation you control, Form 5471 may also apply, and it is one of the information returns the Streamlined procedures expect to be complete.

Savings and investment features inside the app. Instant-access savings features are frequently provided by a partner bank, which can make that balance a bank account with a different institution, and in-app funds can be pooled investment funds, which fall within the other financial account category and may carry PFIC reporting. Read the product terms for each feature you used, not just the main account.

Penalty exposure is per report, not per account, for non-willful violations. In Bittner v. United States (2023), the US Supreme Court held that the non-willful civil penalty applies per report rather than per account. Publication 5569 notes that civil FBAR penalty maxima are adjusted annually for inflation and that there is no minimum. Willful violations carry far higher penalties, which is exactly why an accurate non-willful narrative, supported by a complete filing, matters.

What records should you gather before filing?

Before we prepare late FBARs or a Streamlined submission, we ask for a full transaction export for every year in scope, the account number or IBAN for each currency pocket, the legal name and address of the entity that maintains the account, details of any savings or investment features and the institution behind them, and your filed US returns and FBARs for the same period. Having this in hand lets us value each account correctly, reconcile the income to your returns, and write a late-filing explanation that is accurate rather than generic.

The bottom line for US persons in the UK: do not rely on the argument that e-money is not a deposit. Report the account, value every currency pocket at the Treasury year-end rate, and choose between late FBAR filing and the Streamlined Foreign Offshore Procedures based on whether your returns were right. Our team prepares late FBARs, Form 8938 and full Streamlined submissions for US-UK clients every week, and a complete, conservative filing remains the most reliable way to close the gap.