As an American citizen living in Hong Kong, you might juggle multiple overseas accounts. Foreign bank account reporting rules don’t just affect your peace of mind. Skipping them can trigger steep fines. In 2025 a willful failure to file an FBAR can cost up to $165,353 or 50% of your account balance per violation. That can be more than the money you’re holding outside the United States.

Key idea: You can avoid penalties by knowing which forms to file, when to file them, and how to keep records. This guide covers everything from thresholds to deadlines (plus a few overseas bank account reporting tips you can use today). At American Pacific Tax (AP), we help U.S. citizens in Hong Kong handle these reporting requirements with confidence.

Determine your filing need

Define U.S. person

You must first confirm you’re a U.S. person for reporting. A U.S. person includes citizens, green card holders, resident aliens, and many domestic entities such as corporations, partnerships, LLCs, trusts, and estates (per the Bank Secrecy Act).

Recognize reportable accounts

You need to report foreign financial accounts held at overseas institutions. This includes bank accounts, brokerage accounts, mutual funds, and similar assets. Whether the account produced taxable income doesn’t matter for FBAR purposes.

Calculate reporting thresholds

The FBAR threshold kicks in when your total foreign account value exceeds $10,000 at any point during the year. For FATCA you face separate FATCA reporting thresholds (for IRS Form 8938). For 2024 your specified foreign financial assets must exceed $50,000 on the last day or $75,000 at any time to trigger reporting.

Compare FBAR vs Form 8938

File FinCEN Form 114 (FBAR)

You use FinCEN Form 114 to report foreign bank and financial accounts. You file electronically through the BSA E-Filing System (paper filing is possible only with special approval). FBAR is due April 15, with an automatic extension to October 15. Find more on IRS foreign account disclosure.

File IRS Form 8938

Form 8938 (Statement of Specified Foreign Financial Assets) goes with your tax return (Form 1040). It covers assets beyond bank accounts, such as foreign stocks and partnerships. You meet these FATCA reporting obligations when your overseas asset value crosses the FATCA thresholds (see above). This form is due April 15 as part of your expat return, with any tax extensions carrying over.

Meet your filing deadlines

FBAR due dates and extension

FBAR is an annual report for the prior calendar year. It’s due April 15 following the year you’re reporting. You get an automatic extension to October 15 if you miss the first deadline, no request needed.

Form 8938 deadline

You attach Form 8938 to your individual income tax return (Form 1040). It’s due April 15 (with extensions available if you file Form 4868). Plan ahead so you’re not racing the clock.

Avoid penalties with recordkeeping

Understand potential fines

Civil penalties for nonwillful FBAR violations can reach $16,536 per report (adjusted annually). Willful violations are steeper, up to $165,353 or 50% of the account balance per violation. Criminal penalties may also apply in severe cases. Good news—timely compliance keeps you safe.

Keep proper records

You need a clear paper trail for each foreign account. Aim to keep:

  • Periodic statements showing maximum year-end values
  • Records of currency conversions (use Treasury’s year-end rates)
  • Copies of filed FBAR and Form 8938
  • Supporting documents for joint accounts, trusts, and loans

Keep all records for five years from the FBAR due date (per FinCEN guidance).

Quick recap and next step

  1. Confirm if you qualify as a U.S. person.
  2. Note your foreign accounts and check if they cross thresholds.
  3. File FBAR (FinCEN Form 114) and Form 8938 if needed.
  4. Meet April 15 deadlines, and use the October 15 extension for FBAR.
  5. Keep detailed records for at least five years.

Choose one step today, and see how much simpler overseas compliance can feel. You’ve got this. If you want help, our team at American Pacific Tax is ready to guide your expat tax return preparation and foreign account compliance.

Frequently asked questions

What counts as a U.S. person for FBAR?

A U.S. person includes citizens, green card holders, resident aliens, and domestic entities such as corporations, partnerships, LLCs, trusts, and estates. If you fall into any of these categories, you meet the FBAR filer definition.

Can you file FBAR late?

Yes, you get an automatic extension to October 15 if you miss the April 15 deadline. While no formal request is needed, file as soon as possible to avoid potential penalties.

Do you need both FBAR and Form 8938?

Possibly. FBAR and IRS Form 8938 have different thresholds and asset definitions. If your accounts exceed both sets of requirements, you must file both. Check the thresholds and asset types above to decide.