Filing FinCEN Form 114 (FBAR) is a critical compliance requirement for U.S. persons with foreign financial accounts. However, mistakes happen. Whether you missed an account, entered the wrong value, or forgot to report signature authority, the IRS allows you to file an amended FBAR to correct the error. This guide explains how to revise a previously filed FBAR, including a step-by-step walkthrough, deadlines, and real-world examples.
🛠️ When Should You Amend an FBAR?
You should file an amended FBAR if you discover any of the following errors in your original submission:
- Omitted one or more qualifying foreign accounts
- Entered incorrect maximum values or account numbers
- Selected the wrong financial interest or signature authority status
- Filed under the wrong name or tax ID
Even if you believe the error is minor, it is best to file an amendment proactively. Prompt correction can reduce the risk of penalties, especially if the mistake was non-willful.
📝 Step-by-Step: How to File an Amended FBAR
Step 1: Access the BSA E-Filing System
Visit the BSA E-Filing System. You will use the same portal as the original filing.
Step 2: Download the FBAR PDF (FinCEN Form 114)
Use the offline fillable PDF version of FinCEN Form 114, which can be completed and submitted through the E-Filing portal.
Step 3: Check the “Amended” Box
At the top of the form, there is a checkbox labeled “Amended.” Check this box to indicate you are correcting a previous FBAR filing.
Step 4: Enter Corrected Information
- Make the necessary corrections (e.g., add missing accounts, fix values or account numbers)
- Re-enter all accounts—not just the ones you’re correcting
- Include original filing date in the designated field
Step 5: Add an Explanation in the Remarks Section
Include a brief explanation such as: “Amended FBAR to include omitted account at XYZ Bank” or “Corrected account number and balance.” This helps FinCEN understand the change and may support penalty mitigation.
Step 6: Submit Electronically
Upload the revised FBAR through the BSA E-Filing portal and submit. You’ll receive an electronic confirmation just like with your original filing.
Step 7: Retain Records
Keep a copy of the amended FBAR, submission receipt, and any related documentation for at least five years.
📌 What You Need to Include in an Amended FBAR
- Your full legal name and SSN or EIN
- All foreign accounts to be reported—not just amended ones
- Corrected maximum values and account types
- The original filing date and BSA identifier (if known)
💬 Example Scenarios
Example 1: Missed an Account
James originally reported five accounts but later realized he omitted a checking account in the UK that had $12,500 at its peak. He filed an amended FBAR, including all six accounts, and noted the correction in the remarks. No penalty was assessed due to prompt correction.
Example 2: Wrong Account Number
Maria entered the wrong account number for a brokerage account in Germany. She amended the FBAR with the correct number and clarified the correction in the remarks field. Her amendment was accepted without issue.
⏱️ Deadline for Amending
You can amend an FBAR at any time. However, it’s best to correct errors as soon as you detect them to avoid possible penalties. If the correction occurs after receiving an IRS notice, the amendment may still reduce penalties, but may not eliminate them entirely.
⚖️ Penalty Implications
Correcting an FBAR error voluntarily—before IRS contact—is considered a “good faith” act and can help avoid non-willful penalties (up to $10,000 per violation). If willful conduct is suspected, the IRS may impose heavier penalties (up to the greater of $100,000 or 50% of the account value).
✅ Summary
Filing an amended FBAR is a straightforward but essential process for maintaining compliance with U.S. foreign account reporting rules. Whether the error was accidental or due to oversight, prompt correction through the BSA E-Filing System can help mitigate penalties and demonstrate good faith. Always retain supporting records, and if your situation is complex or high-risk, consult a tax professional experienced in international compliance.
