I would, just to be safe. There are no tax implications until you sell that cryptocurrency and convert it to US dollars.
I would treat cryptocurrency just like gold, hard currency and real estate. That is, these assets are generally not reportable for foreign account purposes when held directly, but become reportable when they are stored in a foreign financial account.
A taxpayer who has placed the value of his or her bitcoin in a virtual wallet hosted overseas should include cryptocurrency for purposes of aggregation and reporting FBAR amounts. This type of approach would, at the least, provide the taxpayer with a reasonable and conservative approach.
