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Swiss Numbered Accounts For FBAR

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Swiss Numbered Accounts For FBAR

In the realm of international finance, Swiss numbered accounts are often perceived as a symbol of privacy and security. These accounts, known for their anonymity and stringent privacy regulations, have attracted a significant number of clients over the years. However, for U.S. taxpayers, holding such accounts comes with specific legal responsibilities, particularly concerning the Foreign Bank Account Report (FBAR). This article aims to elucidate the intricacies of Swiss numbered accounts concerning FBAR, detailing the relevant regulations, obligations and processes involved.

Swiss numbered accounts are unique financial instruments characterized by the use of numbers rather than names to identify account holders. This system is designed to provide an additional layer of privacy. Despite this anonymity, Swiss banks still maintain detailed records of account holders’ identities, ensuring compliance with international banking laws.

Legal Framework and Regulations

Swiss numbered accounts for FBAR are regulated under the Bank Secrecy Act (BSA) of 1970, specifically by the regulations outlined in the Financial Crimes Enforcement Network (FinCEN) Form 114, commonly referred to as the FBAR. The BSA mandates U.S. persons to report their financial interests in foreign financial accounts if the aggregate value exceeds $10,000 at any point during the calendar year.

The key regulations governing these accounts are:

  • 31 U.S.C. 5314: This statute requires U.S. persons to report foreign financial accounts and maintain records.
  • 31 CFR 1010.350: This regulation specifies the FBAR filing requirements.
  • 31 CFR 1010.420: This outlines the recordkeeping requirements for foreign financial accounts.

These regulations are enforced by the Internal Revenue Service (IRS) and FinCEN, with penalties for non-compliance ranging from civil fines to criminal charges.


The obligation to file an FBAR applies to U.S. persons, which includes:

  • U.S. citizens
  • U.S. residents
  • Entities such as corporations, partnerships, limited liability companies, trusts, and estates formed under U.S. laws

These individuals and entities must report if they have a financial interest in or signature authority over one or more foreign financial accounts with a total value exceeding $10,000 at any time during the calendar year.

Process Steps for Filing FBAR

The process of filing FBAR for Swiss numbered accounts involves several detailed steps to ensure compliance with the legal requirements. A guide to the steps involved is presented below:

1. Identification of Foreign Financial Accounts

The first step involves determining if any foreign financial accounts meet the FBAR reporting threshold. U.S. persons must report foreign financial accounts if the aggregate value of these accounts exceeds $10,000 at any time during the calendar year. Specifically, for Swiss numbered accounts, one should identify all accounts held in Switzerland under a numbered account system.

  • Reviewing Account Holdings: All financial accounts must be examined to determine if they qualify as foreign financial accounts.
  • Threshold Evaluation: It should be verified that if the total value of all foreign accounts exceeds $10,000 at any point during the calendar year.

2. Gathering Information

After identifying the accounts that require reporting, the next step is to gather detailed information about these accounts. The information required includes:

  • Bank Name and Address: The name and address of the Swiss bank where the numbered account is held.
  • Account Number: The specific numbered account identifier used by the Swiss bank.
  • Account Type: The type of account (e.g., savings, checking, securities).
  • Maximum Account Value: The highest balance in the account during the calendar year.
  • Account Holder Information: Details about the account holder, including name, address, and taxpayer identification number.

3. Filing FinCEN Form 114

Filing the FBAR, officially known as FinCEN Form 114, is the critical step in the process. This form must be submitted electronically through the BSA E-Filing System.

  • Accessing the BSA E-Filing System: The BSA E-Filing System website should be visited to begin the filing process.
  • Completing the Form: All required information should be entered accurately including details of each Swiss numbered account.
  • Submission Deadline: It should be ensured that the form is submitted by April 15 of the following year. An automatic extension to October 15 is available, but it must be requested.
  • Confirmation: After submission, a confirmation notice should be received. This confirmation should be retained for the records.

4. Maintaining Records

Maintaining proper records of foreign financial accounts is crucial for compliance. U.S. persons are required to keep records for at least five years from the due date of the FBAR.

  • Account Statements: Copies of bank statements and other financial documents that substantiate the information reported on the FBAR should be preserved.
  • Identification Documents: Identification documents and any correspondence related to the Swiss numbered accounts should be kept.
  • Record Retention: It should be ensured that records are stored securely and can be easily accessed if needed for audit or verification purposes.

Additional Considerations

  • Compliance Reviews: Compliance with FBAR requirements should be regularly reviewed to ensure ongoing adherence to reporting obligations.
  • Legal Advice: Seeking legal advice or consulting with a tax professional should be considered to address any uncertainties or complex situations related to foreign accounts.
  • Voluntary Disclosure: If previous FBAR filings were missed, it should be considered participating in the IRS’s voluntary disclosure programs to mitigate potential penalties.

Dimov Tax & CPA Services for Swiss Numbered Accounts and FBAR

At Dimov Tax & CPA Services, comprehensive support is provided to clients with Swiss numbered accounts to ensure compliance with FBAR regulations. The services offered include:

  • Consultation and Assessment: Evaluating clients’ foreign account holdings to determine FBAR filing obligations.
  • Documentation Assistance: Assisting in gathering and organizing the necessary documentation for accurate reporting.
  • FBAR Filing: Preparing and filing FinCEN Form 114 on behalf of clients, ensuring timely and accurate submission.
  • Recordkeeping Solutions: Providing systems and advice for maintaining required records in accordance with regulatory requirements.
  • Audit Representation: Offering representation in case of audits or inquiries by the IRS or FinCEN regarding foreign accounts.
  • Legal Compliance Advisory: Advising on strategies to mitigate risks associated with non-compliance, including voluntary disclosure programs and penalty mitigation.

Key Considerations for Swiss Numbered Accounts

When dealing with Swiss numbered accounts, several considerations should be kept in mind to ensure full compliance and avoid potential penalties:

  • Privacy vs. Transparency: While Swiss numbered accounts offer a high degree of privacy, U.S. regulations demand transparency. Ensuring all accounts are disclosed and reported is crucial.
  • Penalties for Non-Compliance: Non-compliance with FBAR regulations can result in severe penalties. Civil penalties can be as high as $12,921 per violation for non-willful violations, while willful violations can incur penalties up to the greater of $129,210 or 50% of the account balance at the time of the violation. Criminal penalties may also apply.
  • Voluntary Disclosure Programs: For those who have previously failed to report foreign accounts, the IRS offers voluntary disclosure programs which can help mitigate penalties and reduce the risk of criminal prosecution.
  • Changing Regulations: The landscape of international financial regulation is continually evolving. Staying informed about changes in both U.S. and Swiss laws is essential for ongoing compliance.


Swiss numbered accounts present a unique blend of privacy and complexity, particularly for U.S. taxpayers subject to FBAR requirements. Understanding the legal framework, fulfilling reporting obligations, and maintaining proper records are essential steps to ensure compliance and avoid significant penalties. Dimov Tax & CPA Services offers specialized expertise to navigate these challenges, providing clients with peace of mind and comprehensive support in managing their international financial obligations.

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