I live in the US and have a transferwise account with money in US Dollars and Euros. Do I have to declare the EURO account as a foreign bank account?

[MinhT1 · Accepted solution]

Your Transferwise account is a borderless account which is regulated by the Financila Coduct Authority in the UK, and as such is considered as a foreign account for US residents and citizens.

Therefore, if your Transferwise had a balance (including all currencies) of more than $10,000 anytime during 2019, you have to file a FBAR report.

Please read this FINCEN article for more information.

[mvier]

I asked that specific question to Transferwise and they said I did not. I would tend to agree with you though but why would their customer support people state the opposite ?

[Critter-3]

Just  CYA ... it doesn't cost you anything to file the FBAR and it doesn't hurt you in any way so just file one to be safe. 

[kay321]

When you say "more than $10,000" is that including or excluding your USD balance?

As I understand it, TransferWise keeps USD balances in a US bank.

[DaveF1006]

It depends. Any account overseas is a foreign account regulated by foreign regulators.  If there is more than $10K in the accounts kept overseas, it has an FBAR requirement whether USD balances or otherwise. Besides, as Critter-3 expresses, it doesn't cost anything to file the FBAR and may avoid legal ramifications in the long run. I am sure you can do without the potential headaches involved.