As per the notice, users in the United States with a financial account such as foreign banking account, securities account, or brokerage account, exceeding over $10,000 in any given year are required to comply with FBAR by filing Form 114.
The FinCEN notice read:
A financial account also includes a savings account, demand, checking, deposit, time deposit, or any other account maintained with a financial institution. Other accounts include the one with a credit card, an insurance policy, securities derivatives, mutual funds, etc.
One is obligated to report even if the user has no associated taxable income. The form must be filed before the financial year-end, i.e. before April 15th.
Under the current FinCEN regime, crypto users are not required to comply with FBAR and disclose their overseas crypto asset holdings. However, If the existing rules do get amended, crypto users using foreign cryptocurrency exchanges would have to disclose their holdings exceeding the $10,000 by the end of the current financial calendar.
So far, neither the U.S. Treasury nor FinCEN has issued any additional comment on the notice, including when the notice will get amended.