MonsieurMD
Returning Member

FBAR/FinCEN 114 and currency exchange services

Hello, I am a US expat living in France.

 

Over the years, I have reported my foreign bank accounts consistently on the FBAR/FinCEN 114, but now I am concerned that I should be reporting my use of Wise (formerly TransferWise) to make occasional currency exchange transfers between my bank account in France and the US.

 

Note, I do not have a Wise Borderless account where one can hold a balance. Rather, when I want to make a transfer, I wire money to one of Wise's bank accounts (from my French account which is already reported on my FBAR). Wise then makes the transfer between their own accounts and credits my bank in the US. 

 

To be safe, I am planning to report my use of Wise on the FBAR, but I am wondering what I should put as the maximum account value? Should it correspond to the maximum amount that I have transfered in a given year? Or is it more accurate to say the value is zero, given that I do not have a financial account with them that actually holds a balance?

 

Any insights would be appreciated. Thank you.