Leo, a U.S. citizen, has signature authority over his employer's bank account in London, which holds $500,000, but no financial interest in it. His employer is not a U.S. financial institution or listed exempt entity. Does Leo have an FBAR filing requirement?
A U.S. person with a financial interest in or signature or other authority over foreign financial accounts exceeding $10,000 in aggregate must file an FBAR. Signature authority alone is enough, subject to specific exceptions (for example certain officers of publicly traded or regulated U.S. entities). Leo reports the account but not its income, which belongs to the employer. Source: 31 CFR 1010.350(f); Pub. 54 (12-2025), FinCEN Form 114; FBAR instructions. Tax year: 2025 (law as of 31 Dec 2025).
Thinking only account owners report foreign accounts.
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