If you moved to the United States from Ukraine, or you hold a green card while your family and your banking are still in Kyiv or Lviv, the FBAR rules that apply to you are exactly the same as for anyone else. The reporting does not care which country the account is in.
What differs is the set of practical questions, and those come up in nearly every conversation we have with Ukrainian clients.
The rule, briefly
FBAR is triggered when the combined highest balance across all of your foreign accounts crosses $10,000 at any point in the calendar year, even for a single day. Not per account, not the year-end balance. The full version is in FBAR filing: the key points.
It applies to US persons, which includes green card holders and anyone treated as a US resident for tax purposes, whether or not they currently live in the States.
Which Ukrainian accounts count
More than people expect. In practice we regularly find:
- Ordinary bank accounts at PrivatBank, Monobank, Oschadbank, Raiffeisen and others, including the card account somebody has kept open since university
- Deposit accounts in both hryvnia and foreign currency
- Brokerage and investment accounts
- Accounts held jointly with a spouse, parent or sibling
- Accounts where you hold signature authority but no ownership, for example a parent's account you were added to in order to help them, or a company account you can sign on
That last category is the one that surprises people most. Being able to operate an account can be enough to make it reportable even where none of the money is yours.
The account you forgot about
By far the most common Ukrainian-specific pattern: someone left, built a life in the States, and never closed the account they had at home. It has some balance sitting in it. Nothing moves through it. It does not feel like part of their financial life at all.
It is still an account. If it pushes the combined total across the line in any year, it is reportable for that year, dormant or not.
The same goes for an account you emptied and abandoned. What matters is the highest balance it reached during the year, not what is in it now.
Accounts you cannot currently access
Since 2022 this has come up constantly, and it deserves a direct answer: difficulty accessing an account does not remove the reporting obligation.
If the account exists and you have a financial interest in it or authority over it, it is reportable, even if the branch is closed, the region is occupied, or you cannot practically move the money.
What that situation does affect is the evidence. Reconstructing a highest balance without statements is a real problem, and it is a solvable one. Do the best reconstruction you can from what you have, document how you arrived at the figure, and keep that documentation. A reasoned, documented estimate is a far better position than silence.
Converting hryvnia balances
Balances get reported in US dollars, converted using the official year-end exchange rate published by the US Treasury for the year in question, applied to each account's highest balance.
Two things people get wrong here:
- They convert using the rate on the day the balance peaked. The convention is the Treasury year-end rate.
- They assume hryvnia volatility means a small account cannot matter. Given the exchange rate movements of recent years, run the arithmetic rather than eyeballing it. Accounts that felt insignificant in local terms have crossed the threshold in combination more than once.
First year in the US
If you arrived recently, your first year is often a dual-status or part-year situation, and whether FBAR applies for that year depends on your residency position for it.
This is worth getting right rather than assuming in either direction. Some people file when they did not need to, which is harmless. Others assume their first year cannot count, which is not.
Where this usually goes
Most Ukrainian clients we see in this position have no tax to pay and a report to file. The money was already taxed, or the account earned almost nothing, and the only thing missing is a form nobody told them existed.
If several years are unfiled, that is a normal situation with a defined route back, described in you missed FBAR: here is the path back.
If you would rather not work out which of these applies to you on your own, describe your situation in one sentence. We do this in English and Ukrainian.
Thresholds, deadlines and penalty amounts change every filing year. This guide is reviewed against the current year, and it is educational rather than advice about your own situation. Before you act on anything here, check it with us.