Here’s the issue: The federal government has a requirement to file a specific report if you have financial accounts outside the U.S. that have more than $10,000 in the account at any point during the year.
This filing requirement applies to the organization and any individual with signature authority on the account. That means your ministry must file reports (if your accounts clear the threshold on any day of the year) and every check signer must as well.
For just a little more detail, you can read the other posts on this blog at this tag.
If you want some deep detail, check out an article by Karen Nakamura, at Corporate Taxation Insider: Foreign bank account reporting.
Here is her opening sentence which describes the new form number and the federal agency regulating the issue:
FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR, formerly Form TD F 90-22.1), is used by the Financial Crimes Enforcement Network (FinCEN), an agency of the Treasury Department, to track the worldwide movement of money controlled by U.S. persons.
Here is a more technical definition of who must file:
Potential FBAR filers are U.S. persons, commonly referred to as account holders, including a citizen/resident, corporation, partnership, or trust/estate with a financial interest in or signature authority over any foreign financial account (i.e., an account outside the United States) with more than $10,000 in aggregate value in a calendar year.
To make the point yet again, both the organization with deposits over the threshold must file and anyone with signature authority. That could include your U.S. based CFO, treasurer, or senior accounting staff. If you have to file, the requirement would fall on your field program manager and finance staff who can sign on the account.
If you are a CFO or board treasurer with field programs, you might want to read the full article linked above.
Remember, June 30 is the filing deadline. No extensions. Significant fines are possible.