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FBAR filing: 15 questions for US corporate treasuries before April 15th deadline

For US companies, reporting foreign bank and financial accounts (FBAR) to the Financial Crimes Enforcement Network (FinCEN) is vital.

Given that the treasury department is tasked with monitoring and managing an organization’s bank relationships, worldwide financial accounts, and transactions, with a steadfast commitment to accurate and updated financial records, corporate treasury is best positioned to lead in navigating the complexities of FBAR filing.

With the deadline to file FBAR coming up on April 15th, it is imperative that US corporate treasuries consider these 15 important questions to enable timely, efficient, accurate, and secure FBAR information reporting and tracking.

Besides well-preparedness, asking these questions will help corporate treasury in managing the intricacies of FBAR filing to ensure regulatory compliance, financial transparency, integrity, and accountability, avoid severe penalties, and align with the US government’s efforts to combat illicit financial activities.

Here are the top 15 questions treasury departments of US companies should ask of themselves regarding reporting of their foreign bank and financial accounts before the April 15th due date:

As a treasury executive:

  1. Do you understand the potential consequences of failing to comply with FBAR reporting and recordkeeping requirements?
  2. Are you familiar with the types of financial accounts that fall under the scope of FBAR reporting requirements?
  3. Have you accurately identified and documented all relevant foreign bank and financial accounts held by your corporation or its subsidiaries that meet the reporting threshold set by the IRS for FBAR filing?
  4. Are you aware of the key nuances of FBAR filing related to financial accounts, financial interest, and signatory authority, which if ignored, can lead to filing errors?
  5. Do you know how to determine if individuals within your organization have financial interest or signatory authority over foreign financial accounts?
  6. Are you informed about how corporate signers (employees with signature authority) should handle FBAR filing obligations?
  7. Are you cognizant of the exceptions that exist for FBAR filing?
  8. Do you know how the reporting threshold for FBAR is calculated?
  9. Do you possess knowledge of the exchange rate that should be used for FBAR reporting?
  10. Are you acquainted with the reporting methods available for filing FBAR?
  11. Are you knowledgeable about the information necessary to file FBAR and which records or statements associated with such filing ought to be maintained?
  12. Do you know how to ensure that efficient, accurate, and up-to-date reporting and tracking  have been done in alignment with FBAR requirements?
  13. Are you aware of the measures that should be taken to ensure the security and confidentiality of sensitive financial information during the FBAR filing process?
  14. Do you have employees or staff members with the requisite competence or expertise to accurately manage FBAR reporting?
  15. Have you considered the potential benefits of seeking external experts to streamline the complexities of FBAR filing or outsourcing the entire FBAR filing process to qualified professionals with specialized experience in reporting foreign financial accounts?

Exploring answers to the questions outlined above will assist corporate treasurers and their teams in gaining a comprehensive understanding of their FBAR obligations and enhancing their overall preparedness for such filings.

By systematically addressing each question, treasury professionals shall acquire valuable insights tailored to their specific situation, enabling them to maneuver the intricacies of FBAR reporting requirements with confidence, and seek expert guidance when needed.

In addition to asking the right questions, you can also benefit from attending Strategic Treasurer’s upcoming FBAR webinar, listening to their podcast to understand the various strategies for managing FBAR compliance, downloading their FBAR Filing and Treasury whitepaper, and watching CTMfile’s video on treasury’s key responsibility for reporting foreign bank and financial accounts. Details of the webinar, the podcast, the whitepaper, and the video are posted below:


⃰ Disclosure: Strategic Treasurer owns CTMfile.

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