FinCEN extends deadline for non-financial interest filers


The Financial Crimes Enforcement Network (FinCEN) recently issued guidance (FIN-2023-NTC5), extending to April 15, 2025, the deadline for filing a Report of Foreign Bank and Financial Accounts (FBAR) for certain individuals with signature authority over, but no financial interest in, one or more foreign financial accounts. ​​​​​​​


Every year since 2011, FinCEN has issued an extension to similarly situated individuals. In order to be eligible for the reporting extension under the notice, an individual must satisfy specific criteria with respect to certain employer-owned foreign financial accounts.

FinCEN extended the deadline in light of a notice of proposed rulemaking that it issued on March 10, 2016. These proposed regulations expand and clarify filing exemptions for certain U.S. persons with signature authority, or any other authority, over foreign financial accounts, and have yet to be finalized. The extension applies to individuals with signature authority held during the 2023 calendar year, as well as all reporting deadlines extended by prior notices.



Cory Perry

Washington DC, Washington DC

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