Here is a link to FINCEN that has more information regarding foreign financial accounts.
I don't know for certain, but my opinion is that you cannot subtract the amount of cash for distribution. The money was in your account over which you had signature authority. It is not a formal escrow account (and I am not sure that meets any exceptions). The penalties are too great to error on the side of not filing the proper reports. That's my two cents...
https://www.fincen.gov/report-foreign-bank-and-financial-accounts
**Disclaimer: Effort has been made to offer correct information; but due to the discussion forum limitations, the poster disclaims any legal responsibility for the accuracy of the poster's response**
