FinCEN Notice 2020-2: FBAR Filing Requirement for Virtual Currency

Bitcoin Research — Law, Regulation, Markets & Origins (2026)

Fincen

2020-12-31

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Research, not advice. Part of the Bitcoin research archive (October 2026). Claims labelled unverified, contested or fringe are reported, not endorsed; statuses of bills and rules are as of the date checked. Government, court and patent records are public domain; the research notes are CC BY 4.0.

Report of Foreign Bank and Financial Accounts (FBAR)
                        Filing Requirement for Virtual Currency

                                   FinCEN Notice 2020-2

Currently, the Report of Foreign Bank and Financial Accounts (FBAR) regulations do not define
a foreign account holding virtual currency as a type of reportable account. (See 31 CFR
1010.350(c)). For that reason, at this time, a foreign account holding virtual currency is not
reportable on the FBAR (unless it is a reportable account under 31 C.F.R. 1010.350 because it
holds reportable assets besides virtual currency). However, FinCEN intends to propose to amend
the regulations implementing the Bank Secrecy Act (BSA) regarding reports of foreign financial
accounts (FBAR) to include virtual currency as a type of reportable account under 31 CFR
1010.350.