Do I need to file an FBAR for an account I only have signature authority over?

Understand what authority means

For FBAR purposes, signature or other authority generally means the authority, alone or with another person, to control the disposition of money or other property in an account by direct communication with the institution maintaining it. A requirement for two signatures does not by itself eliminate reporting. Having read-only access or receiving statements, without power to direct payments, is different. Review actual bank mandates and account permissions rather than relying only on a job title.

Apply the threshold to all relevant accounts

Consider accounts you own as well as accounts over which you have reportable authority. A foreign business account may exceed the combined $10,000 threshold even if your personal foreign savings are modest. Reporting does not mean you own the company’s money or must include its full balance as personal income. The FBAR asks for the relationship to the account, and the signature-authority section distinguishes this situation from a financial interest.

Check exceptions before relying on the employer

Certain officers and employees of specified regulated or publicly traded entities may qualify for exceptions when they have no financial interest. These exceptions have detailed conditions; an ordinary privately held foreign employer is not automatically covered. An entity’s own FBAR also does not automatically satisfy every employee’s individual obligation. Any special filing deferral must be checked against current FinCEN guidance for the specific person and reporting year rather than treated as a permanent exemption.

Distinguish the FBAR from Form 8938

Signature authority alone generally does not create a Form 8938 obligation if you have no interest in the asset under that form’s rules. By contrast, it can be enough for an FBAR. Other ownership rights, beneficial interests, or an interest in the business may change the separate analysis. Request account details early from the employer and preserve evidence of when authority began or ended. Protect account information while arranging access for the person preparing your report.

Common mistakes

• Assuming a second required signature prevents FBAR reporting.
• Believing that the employer’s filing always covers individual signers.
• Equating read-only access with authority to move funds.

Filing requirements

• Use FinCEN Form 114 and identify signature authority without a financial interest where appropriate.
• The regular April 15 deadline has an automatic extension to October 15; verify any special relief separately.

Potential penalties

• Unreported signature-authority accounts can create FBAR penalty exposure.
• A reasonable-cause position or other relief requires an individual factual review; lack of ownership alone does not establish an exemption.

Related IRS forms

• FinCEN Form 114
• Form 8938

What to consider next

• Obtain the bank authorization documents and relevant account values.
• Ask the employer which specific exception or official deferral, if any, it believes applies.
• Have Chirino USA assess both your authority and any separate ownership-based reporting.