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.

[Cocinero]

I would tend to agree.  The USD balances appear to be kept in a US bank.  Here's how wise is regulated in each country...
https://wise.com/help/articles/2932693/how-is-wise-regulated-in-each-country

I'm still not 100% sure whether or not to report the USD side.  Also, if you've ever done an FBAR report, you'll know that you also have to choose a country when you declare an amount.  So for those that say, 'sure report it anyway', have you actually done this?  And what country did you choose for the USD?  The question is a bit complicated.

[DaveF1006]

Generally as a safe practice, I mentioned to report it anyway.  I am certain though you are safe not to report the balances that are in the US since US is not an option when you pick a country to report in the FBAR.  

[Cocinero]

That's the question though isn't it... they are held in USD and are the actually in the United States or are the USD that are held in a foreign country.  That's what seems to be at odds here.  And that would make all the difference.

[DaveF1006]

I didn't notice this before now but  MinhT1 addresses in his previous post, our Transferwise account is a borderless account which is regulated by the Financial Conduct Authority (FCA) in the UK, and as such is considered as a foreign account for US residents and citizens.  

Armed with this knowledge, I would say that both USD and Euros are regulated by the FCA and you would list the UK as the foreign country to report on the FBAR for both the USD and Euro balances.

When you list this on the FBAR, mention this is a Transferwise account. I am sure FBAR is well-aware of Transferwise. 

[Cocinero]

Thank you for your kind answer... but for me as an EU customer, it appears that Wise (TransferWise) is regulated by the Bank of Belgium.  In fact, this article at Wise, talks about being regulated in UK, EU, & 48 States.  This makes it unclear to me where the USD is held in that side of the account.  But as an EU customer, it seems that potential Belgium should be listed as where both my Euros and my USD are held (and in fact any other currencies I may choose to have in future), but even writing to them they have not been able to answer me with a direct answer.  Will do my best to choose on the FBAR, but nobody seems to know for sure.

[Cocinero]

Forgot the link:  https://wise.com/help/articles/50VrYRVwHcsYeKzvWbjf3n/how-our-eu-entity-wise-europe-sa-safeguards-cu... 

[DaveF1006]

According to the link, I would also think the that National Bank of Belgium is a safe bet to choose where the funds are located if you had to pick a country.

@Cocinero 

[Cocinero]

I've decided to choose Belgium for the Euros... but I finally got this answer from Wise today.  

"Wise uses local banks to receive and send money.

This means that we hold funds in bank accounts that are local to that fund's currencies.

Meaning that USD balance is help in a US bank. This is also the reason your USD balance account details will have both local details and SWIFT payment details."

So the answer is that USD amounts are kept in US banks... only necessary to report the Euro side.  
Thanks for all the help! Done.

[DaveF1006]

Thank you for sharing this with us and i will be sure to include this answer in future posts.  Transferwise is confusing at best since it is borderless and involves mostly virtual transactions.  Thanks again for your information.

@Cocinero