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FBAR and Colombia Bank Accounts: What US Citizens Must Report

If you are a US citizen, green-card holder, or US tax resident with bank accounts in Colombia, the FBAR filing obligation almost certainly applies to you. The five banks below are among the largest in the country by assets. This post is education-only -- it explains the rule and the banks; it does not estimate your penalty or guarantee any outcome. An Enrolled Agent can review your specific situation.

Sabih Shafi, EA - Enrolled Agent

The Colombian banks US filers report most often

These five institutions are among the largest banks in the country by assets:

  • Bancolombia -- the largest bank in Colombia by assets, and the one whose name appears on more FBAR-relevant account statements than any other.

  • Banco de Bogota -- one of the oldest banks in the country, part of Grupo Aval.

  • Davivienda -- a major Colombian bank with retail and corporate operations.

  • BBVA Colombia -- the Colombian subsidiary of the international BBVA group.

  • Banco de Occidente -- another Grupo Aval bank, based in Cali with nationwide presence.

Use these exact names when you list account numbers on FinCEN Form 114. Do not translate them, abbreviate them, or guess at an English equivalent -- the form wants the name as the bank itself uses it.

The FBAR rule, plainly

FBAR is FinCEN Form 114, and the trigger is aggregate. The rule is not per-account and not per-bank. You must file when the combined maximum value of ALL your foreign financial accounts exceeds USD 10,000 at any point during the calendar year. "All" means every account in every country -- your Bancolombia checking, a Davivienda savings, a BBVA Colombia investment account, and any account anywhere else, all summed together.

Two details catch people off guard every year:

  • Maximum value, not year-end balance. FBAR asks for the highest balance each account reached at any moment during the year. A year-end statement is not enough. You may need monthly statements or the bank's own max-balance figure.

  • Filed separately from your tax return. The FBAR is filed through FinCEN's BSA E-Filing system, not with your Form 1040. The deadline is April 15, with an automatic extension to October 15 -- no extension request is needed, the extension is built in.

How Colombia shares account information with the IRS

Colombia has a Model 1 FATCA agreement with the United States, signed May 20, 2015. Under a Model 1 agreement, Colombian financial institutions report account information to DIAN (Direccion de Impuestos y Aduanas Nacionales), Colombia's tax authority, which then exchanges that information with the IRS. This means the banks above are not reporting directly to the US Treasury; they report to DIAN, and DIAN transmits the data. The practical effect is that the IRS can receive account-balance and payment information from Colombian banks, which makes non-filing visible to both governments.

FBAR and FATCA are separate regimes with separate purposes, but they overlap on the same accounts. Filing the FBAR does not satisfy FATCA reporting, and FATCA reporting does not replace the FBAR.

Start with the full picture

For a deeper look at what Colombian banks report and how to pull the right numbers from a Bancolombia tax certificate, read our main post on the topic:

Call or text (323) 900-0305.

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