FBAR Filing Deadline Extended for Individuals with Signature Authority but No Financial Interest in Certain Accounts, FinCEN Notice 2022-1

The Financial Crimes Enforcement Network (FinCEN) announced a further extension of time for certain individuals to file a Report of Foreign Bank and Financial Accounts (FBAR) in light of ongoing questions regarding the filing requirement and its application to individuals with signature authority over, but no financial interest in, certain types of accounts. The filing due date is extended to April 15, 2024, for individuals whose filing due date for reporting signature authority was previously extended by FinCEN Notice 2021-1.

On March 10, 2016, FinCEN proposed to revise the regulations implementing the Bank Secrecy Act (BSA) regarding FBARs. One of the proposed amendments would expand and clarify the exemptions for certain U.S. persons with signature or other authority over foreign financial accounts. The proposed amendment seeks to address questions raised regarding the filing requirement and its application to the individuals with signature authority over, but no financial interest in, certain types of accounts as outlined in FinCEN Notice 2021-1.

This extension applies to the reporting of signature authority held during the 2022 calendar year, as well as all reporting deadlines extended by previous FinCEN Notices 2021-1, 2020-1, 2019-1, 2018-1, 2017-1, 2016-1, 2015-1, 2014-1, 2013-1, 2012-1, and 2012-2, along with Notices 2011-1 and 2011-2. For all other individuals with an FBAR filing obligation, the filing due date remains April 15, 2023.