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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.

2 Replies
Level 13
Level 13

FBAR/FinCEN 114 and currency exchange services

@MonsieurMD , from your post and information of how WISE works for a standard account, what I get is that  WISE facilities that you are using is  like  Western Union of old time.  It is a conduit for transferring monies  between  two  bank accounts  in two countries  ( in your case ).  Thus it is NOT  a bank account in the traditional sense of the word ( not a savings / checking / investment  )  financial account.  Even in the extreme  case where  you transfer  say $10, 000  from   your French  Savings account ( already reported under FBAR ) to your bank account in  Australia ( also reported  on FBAR )  where  for some reason  the withdrawal takes place immediately but  is not completed/ deposited   for a week ( thus  monies rested in your WISE account for a week ), it still does not require reporting because  it is still a conduit., perhaps a slow one   Therefore I do not believe  this type of account  comes  under the purview of FBAR or FATCA regulations.   

On the other hand  if you had the type called  "account without borders " where monies actually  are held   and can be withdrawn  in any of the allowed / supported currencies , it would need to be reported  because  it is not behaving as conduit -- it is  just an account where monies  are held in one denominated currency and can be  withdrawn/credited in any other denominated currency -- thus meeting the definition of a normal  bank/financial  account that you control.   This would have to be reported for FBAR/FATCA purposes.


Does this make sense ?

Is there more I can do for you ?


Returning Member

FBAR/FinCEN 114 and currency exchange services

Thank you pk, that makes a lot of good sense to me!

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