FATCA for Americans Abroad
The US wants to know about every bank account you have abroad. FATCA is why European banks treat your passport like a biohazard.
FATCA — the Foreign Account Tax Compliance Act — requires foreign financial institutions to report accounts held by US persons to the IRS. In practice, this means that when you walk into a bank in Lisbon or Barcelona and hand over your US passport, the compliance officer does a quick cost-benefit analysis: reporting your checking account to the IRS costs more than the revenue you'll generate. Many banks just say no.
It also means you have reporting obligations on your end — two of them, actually, with different agencies, different thresholds, and different penalties. Here's the full picture.
FBAR vs FATCA — the two reporting obligations
FBAR (FinCEN 114)
- Filed with: Treasury (FinCEN), not IRS
- Threshold: $10,000 aggregate across ALL foreign accounts at any point during the year
- Due: April 15 (auto-extension to Oct 15)
- Filed electronically via BSA E-Filing
- Covers: bank accounts, brokerage, mutual funds, pension accounts with signature authority
- Penalty (non-willful): up to $16,536 per violation
FATCA (Form 8938)
- Filed with: IRS, attached to tax return
- Threshold (expats, single): $200,000 year-end OR $300,000 at any point
- Due: with your tax return
- Covers: same as FBAR plus foreign stocks, partnership interests, financial instruments, life insurance
- Penalty: $10,000 per failure, up to $60,000
Yes, you often report the same accounts on both forms. No, that's not a mistake. Different agencies want the same data in different formats.
Banks that won't reject your US passport
Country-by-country, these are the banks that still accept Americans. "Accept" means they'll open an account — expect extra paperwork and possibly a longer onboarding process.
Wise (EUR/GBP/40+ currencies, no local address needed), Charles Schwab (keep your US account, no foreign transaction fees)
Millennium BCP, ActivoBank (digital). Novo Banco is inconsistent by branch.
CaixaBank (most FATCA-friendly), Santander Spain (slower process). BBVA inconsistent.
BBVA Mexico, Banorte, Santander Mexico. Need CURP + Temporary Resident Card.
TD, RBC, BMO, Scotiabank. Easiest country for Americans to bank in.
HSBC, Barclays, Monzo. Starling has been inconsistent with US citizens.
Behind on filing? The Streamlined Procedures
If you've been living abroad and didn't know about FBAR/FATCA, the IRS Streamlined Filing Compliance Procedures let you catch up without penalties — as long as your failure was non-willful (you didn't know, not that you were hiding money). You'll need to file 3 years of back tax returns and 6 years of FBARs. This program exists at the IRS's discretion and could be modified or closed at any time.
"Non-willful" means you genuinely didn't know. If you knew about the requirement and chose not to file, that's willful — and the penalties are much worse. Get a tax attorney, not just a CPA.
❓ Common Questions
What's the difference between FBAR and FATCA?▾
FBAR (FinCEN 114) is filed with the Treasury Department and covers foreign financial accounts exceeding $10,000 aggregate at any point during the year. FATCA (Form 8938) is filed with your tax return to the IRS and covers foreign financial assets exceeding $200,000 (for expats, single) at year-end or $300,000 at any point. They overlap heavily — most expats file both. Different agencies, different thresholds, different penalties.
What are the penalties for not filing?▾
FBAR: up to $16,536 per violation for non-willful failure, or the greater of $100,000 or 50% of account balance for willful failure. FATCA: $10,000 per failure to file, up to $60,000 if you ignore IRS notices. Plus potential criminal penalties. The IRS Streamlined Filing Compliance Procedures let you catch up without penalties if your failure was non-willful — but the window for this program could close.
Which banks reject Americans because of FATCA?▾
Many smaller European banks refuse US citizens because the FATCA compliance cost isn't worth the revenue from one checking account. Large global banks (HSBC, Barclays, Deutsche Bank) generally accept Americans but may require additional paperwork. US-friendly options vary by country — see our country-specific guides for local recommendations. Digital banks like Wise accept Americans globally.
Not sure where to go?
16 questions. 2 minutes. We'll rank every city in our database for your specific priorities.
Take the quiz →