On December 4, 2018, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced a further extension of time for Report of Foreign Bank and Financial Accounts (FBAR) filings for certain individuals with signature authority over, but no financial interest in, one or more foreign financial accounts. The extension was granted in light of the notice of proposed rulemaking that FinCEN issued on March 10, 2016, which proposes to revise the FBAR regulations.

One of the proposed FBAR regulations would expand and clarify the exemptions for certain U.S. persons with signature or other authority over foreign financial accounts. This proposed amendment seeks to address questions raised regarding the filing requirement and its application to individuals with signature authority over, but no financial interest in, certain types of accounts.

On December 22, 2017, FinCEN issued Notice 2017-1 to extend the FBAR filing date for certain individuals with signature authority over, but no financial interest in, one or more foreign financial accounts to April 15, 2019. FinCEN has previously issued identical extensions that applied to similarly situated individuals. Because the proposed regulations have not yet been finalized, FinCEN is further extending the filing due date to April 15, 2020, for individuals whose filing due date for reporting signature authority was previously extended by Notice 2017-1.

For all other individuals with an FBAR filing obligation, the filing due date remains April 15, 2019.

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