The Report of Foreign Bank and Financial Accounts (FBAR), mandated under the Bank Secrecy Act by the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and enforced via Form 114, demands careful attention from US-based corporate treasury and finance teams.

This reporting requirement obligates U.S. persons (U.S. citizens, permanent residents, dual citizens, corporations, LLCs, partnerships, trusts, and estates) to file an FBAR if the aggregate maximum value of their foreign (located outside of the US) financial account(s) exceeds US$10,000 at any point during the calendar year reported. It's not simply an administrative checkbox—it’s a critical compliance obligation and essential safeguard against regulatory pitfalls and reputational consequences.

The treasury and tax departments generally assume primary responsibility for FBAR reporting. With responsibility for overseeing an organization’s banking relationships, global financial accounts, and transactions, while maintaining accurate financial records, treasury is uniquely positioned to identify reportable foreign accounts of a corporation and guide the FBAR filing process.  

Ensuring prompt, accurate, and efficient FBAR reporting is not only vital for regulatory compliance, but also for penalty avoidance, and risk mitigation.  

Consider the cautionary tale of H. Ty Warner, creator of Beanie Babies. In 2013, Warner pled guilty to tax evasion for hiding millions of dollars in secret Swiss bank accounts—and faced a staggering fine of $53.6 million (50% of the maximum balance stashed away in his unreported foreign account) plus $27 million in back taxes and interest—totalling $80 million.

The $80 million penalty stands as a powerful reminder of the serious consequences of failing to comply with FBAR regulations—particularly for corporations and the treasury and tax professionals who manage their financial reporting. Although this case involved an individual with a formal account interest, similar penalties can apply to corporations and individuals without a formal interest in the account. This makes treasury oversight all the more crucial.

When reporting overseas financial accounts, it is equally important to understand the nuances surrounding financial accounts, financial interest, and signatory authority. Each aspect holds unique challenges—and missteps here can derail filings entirely.

To help corporate treasury teams operationalize these aspects and ease the complexities of FBAR reporting, Strategic Treasurer, a leading treasury consulting firm, is hosting a dedicated virtual workshop titled Filing FBAR with Confidence: Navigating the Regulatory Requirements. ⃰

Designed for treasury and finance professionals, this 90-minute virtual workshop outlines the key aspects of FBAR obligations for U.S.-based organizations. The session will cover:

• FBAR’s legal foundation and enforcement from FinCEN.
• Who must file—as an organization and as individuals with authority.
• How to calculate account values, set reporting thresholds, and apply exchange rates.
• Navigating the BSA e‑Filing System.
• Common missteps and real‑life case studies.
• Penalties for noncompliance, and how to mitigate risk.
• FBAR’s place within related regulations such as FATCA and BOI.
• Leading practices for tracking, documentation, and process governance.
• Interactive Q&A to address unique challenges

Each participant will also receive a private 60-minute consulting session with an FBAR specialist. This one-on-one confidential engagement is intended to address organization-specific questions, clarify complex filing scenarios, and help craft a customized compliance plan tailored to your internal structures, account profiles, and reporting obligations. Additionally, workshop attendees will earn 1.8 CTP credits, demonstrating their ongoing professional development and helping them maintain their competitive edge in a rapidly evolving financial landscape.

This exclusive workshop offers treasury and finance executives a cost-effective way to deepen their understanding of the FBAR reporting process, enhance their preparedness for such filing, avoid costly errors and penalties, exhibit a strong commitment to regulatory compliance and sound governance, and support the U.S. government’s efforts to combat illicit financial activity.

To conclude, FBAR compliance isn’t just about avoiding fines—it’s a mark of responsible treasury and finance leadership, reinforcing corporate financial transparency, and upholding the integrity of the U.S. tax system.

In a shifting compliance environment driven by growing cross-border money movement, noncompliance carries financial, reputational, and legal risks. That’s why it's essential for treasury and finance departments not only to monitor account balances, but also to establish full accountability for filing, documentation, and signatory authority oversight.

Since FBAR filing demands process, discipline, and technical precision—qualities at the heart of treasury and finance excellence—we recommend registering for Strategic Treasurer’s Filing FBAR with Confidence: Navigating the Regulatory Requirements workshop. It’s not just an informational session, but also a strategic investment that turns FBAR compliance from a burden into a strength.

Secure your seat today or write to fbar@strategictreasurer.com—and elevate your finance and treasury team’s FBAR readiness and resilience this August.

 

⃰ Disclosure: Strategic Treasurer owns CTMfile.