Regulatory Alerts2011-10-11
FinCEN Guidance on FBAR Requirements for Former Employees with Signature Authority over Former Employer Accounts
FinCEN issued guidance clarifying that former employees with signature authority but no financial interest in a former employer's foreign financial accounts are not expected to maintain personal records of those accounts. Instead, such individuals must file an FBAR including details about the former employer and their title, as the employer is not required to provide this information due to privacy concerns. This exemption does not apply to current employees, who must file complete FBARs, nor does it cover employment status changes made to evade reporting requirements.
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