@In_Vino_Veritas while generally agreeing with @DianeW777 reply to your specific "facts and circumstances", I would like to generalize the answer ---
1. if your foreign currency holding are through an account in an US financial entity ( whether located in the US or in a foreign branch of the US entity ), you may or may not come under FBAR ? FATCA regs ( depending on the exact facts and circumstances ). .
2. if your foreign currency assets are in a foreign financial entity , with a domestic branch ( US locus), you may still be not subject to FBAR /FATCA regs , depending on the exact facts and circumstances.
3.if your foreign or US dollar account is in a foreign financial entity, then you definitely come under FBAR / FATCA regs..
Point here is that it is not the currency but the account holding entity that determines whether you come under FBAR/FATCA regs or not .
Does this make sense ?
