“I opened a Wise account in the US and the statement shows a US address (Wise US Inc in New York). Does this mean it's not considered a foreign account, and I don't need to report it on my FBAR if the balance goes over $10,000?”
Wise’s current U.S. agreement matches what your statement shows: the provider is Wise US Inc, and its receiving details are not separate bank accounts held by you. Crossing $10,000 in that domestic account alone therefore does not trigger an FBAR, although your other foreign accounts still might.
Your result turns on whether you are a and which legal entity maintains the balance-holding Wise Account—not merely the currency or Wise’s global brand.
The current U.S. personal agreement identifies Wise US Inc—a Delaware corporation with a New York registered office—as the provider of one multi-currency Wise Account. Applying the IRS location test, that account is domestic, so you do not report it or include its balance in the foreign-account $10,000 calculation. [IRS Publication 5569, page 2; Wise US Customer Agreement §§1.1, 3.1 and Definitions]
If you also have a separate balance-holding Wise Account whose applicable agreement identifies an institution outside the United States, and you are a U.S. person, treat that account as foreign. File if the aggregate value of all such foreign accounts exceeds $10,000 at any time during the year. [31 CFR 1010.350(a); FinCEN, “Who Must File the FBAR?”]
If you were neither a U.S. citizen nor a U.S. resident during the relevant calendar year, the individual FBAR requirement does not apply to you—even for an account outside the United States. [31 CFR 1010.350(a)–(b)]
Brand-level statements that “Wise is foreign” do not control: 31 CFR 1010.350 controls, the IRS guide explains the account-location test, and your account-specific agreement identifies the provider.
These steps document the domestic Wise treatment and determine whether anything else requires an FBAR.
For the reporting year
Match the statement to the Wise legal entity
Confirm that the balance-holding account’s statement and agreement name Wise US Inc. The current personal agreement does: it identifies Wise US Inc as the contracting entity and says Account Details are not a bank account held by you. If the applicable agreement instead names a non-U.S. provider for a separate Wise Account, use the foreign-account route. [Wise US Customer Agreement §§1.1, 3.1 and 12.3]
Requirements
Before deciding whether to file
Total only your foreign financial accounts
Exclude the Wise US Inc account. Determine whether the combined value of all genuinely foreign accounts exceeded $10,000 at any time during the calendar year. For a reportable non-dollar account, determine its maximum value in its own currency and convert it using the Treasury exchange rate for the last day of that year. [FinCEN, “Who Must File”; IRS Publication 5569, page 3]
Requirements
Only if the foreign threshold was exceeded
File FinCEN Form 114 if the foreign total crossed $10,000
File electronically through FinCEN’s BSA E-Filing System at https://bsaefiling.fincen.gov/. The deadline is April 15 following the reported year, with an automatic extension to October 15 and no extension request required. Do not attach the FBAR to your federal income-tax return. [IRS FBAR guidance, updated July 30, 2026]
Requirements
After filing
Keep the reportable-account records
Keep the account name, number, foreign institution’s name and address, account type, and maximum annual value for five years from the FBAR due date. [IRS, “Keeping records”]
Requirements
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This answer applies 31 CFR 1010.350, FinCEN and IRS FBAR guidance, and Wise US Inc’s current personal Customer Agreement.
31 CFR 1010.350
The controlling regulation limits FBAR reporting to specified foreign financial accounts held or controlled by U.S. persons.
§1010.350(a)–(b)
(a) In general. Each United States person having a financial interest in, or signature or other authority over, a bank, securities, or other financial account in a foreign country shall report such relationship to the Commissioner of Internal Revenue for each year in which such relationship exists and shall provide such information as shall be specified in a reporting form prescribed under 31 U.S.C. 5314 to be filed by such persons. (b) United States person. For purposes of this section, the term “United States person” means— (1) A citizen of the United States; (2) A resident of the United States.
IRS Publication 5569 (Rev. 3-2022)
The IRS says physical account location controls and illustrates that a foreign institution’s U.S. branch is not foreign.
“What Is a Foreign Financial Account?”
A financial account maintained with a financial institution located outside of the U.S. is a foreign financial account. It is the location of the account, not the nationality of the financial institution, that determines whether an account is “foreign” for FBAR purposes. Example: An account maintained with a branch of a U.S. bank physically located in Germany is a foreign financial account. Example: An account maintained with a branch of a French bank physically located in Texas isn’t a foreign financial account.
FinCEN Form 114 guidance
FinCEN establishes the combined-balance threshold for a U.S. person’s foreign accounts.
“Who Must File the FBAR?”
A United States person that has a financial interest in or signature authority over foreign financial accounts must file an FBAR if the aggregate value of the foreign financial accounts exceeds $10,000 at any time during the calendar year.
Wise US Personal Customer Agreement v1.4
Wise’s current U.S. personal terms identify the U.S. contracting entity and explain that receiving details are not a separate bank account held by the customer.
§§1.1, 3.1, 12.3 and Definitions
Last updated: 27 July 2026 - Version 1.4 This Customer Agreement is a contract between you, as an individual (“you”) and Wise US Inc. Wise US Inc. is a company incorporated under the laws of Delaware. Our registered office is located at 30 W 26th Street, Floor 6, New York, NY 10010. Wise Account means a multi-currency account held by customers at Wise, which may include a Jar. When Wise provides you with Account Details (as described further below), these Account Details are a means to receive funds from third parties into a bank account held by Wise and its affiliates. Wise can credit your Wise Account when you use these Account Details, and they are not a bank account number for a bank account held by you.
IRS FBAR guidance
The current IRS page gives the deadline, automatic extension, electronic filing route, and five-year record rule.
“When to file,” “How to file,” and “Keeping records”
The FBAR is an annual report, due April 15 following the calendar year reported. You’re allowed an automatic extension to October 15 if you fail to meet the FBAR annual due date of April 15. You don’t need to request an extension to file the FBAR. You must file the FBAR electronically through FinCEN’s BSA E-Filing System. You don’t file the FBAR with your federal tax return. Generally, you must keep these records for five years from the due date of the FBAR.
IRS Publication 5569 (Rev. 3-2022)
The IRS explains how to determine and convert a reportable foreign account’s maximum value.
“Determining Maximum Account Value,” page 3
The maximum value of an account is a reasonable approximation of the greatest value of currency and non-monetary assets in the account during the calendar year. Then, convert the maximum account value for each account into U.S. dollars using the exchange rate on the last day of the calendar year. When converting between a foreign currency and U.S. dollars, use the Treasury Reporting Rates of Exchange for the last day of the calendar year.
These are the official rules and account terms as published on the cited dates; rules and terms can change.
This is general information about official processes, not legal advice; SettleKit is not a law firm.
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