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Do I need to report to FInCEN if I had greater than $10,000 worth of bitcoin in a foreign bitcoin exchange?
Lets look at possible use cases: If you ever converted your cryptocurrency to cash on a foreign exchange, then **YES** you had to report. That means if you ever daytraded and the US dollar (or other fiat) amount was $10,000 or greater when you went out of crypto, then you need to report. Because the regulations stipulate you need to report over $10,000 at any point in the year. If you DID NOT convert your cryptocurrency to cash, and only had them on an exchange's servers, perhaps traded for other cryptocurrency pairs, then NO this did not fall under the regulations. Example, In 2013 I wanted to cash out of a cryptocurrency that didn't have a USD market in the United States, but I didn't want to go to cash on a foreign exchange specifically for this reason (amongst others). So I sold my Litecoin on BTC-E (Slovakia) for Bitcoin, and then I sold the Bitcoin on Coinbase (USA).  (even though BTC-E had a Litecoin/USD market, and then I could day trade the swings easily to make more capital gains, but I wanted cash in my bank account AND didn't want the reporting overhead). Read the regulations yourself. Financial instruments that are reportable: Cash (fiat), securities, futures and options. Also, http://www.bna.com/irs-no-bitcoin-n17179891056/ whether it is just in the blockchain or on a server, IRS and FINCEN said bitcoin is not reportable on FBAR. When they update their guidance, it'll be in the news. The director of FinCEN is very active in cryptocurrency developments and guidance. Bitcoin has been around for six years, it isn't that esoteric and the government isn't that confused on what it is (IRS and FinCEN's hands are tied by Congress in how to more realistically categorize cryptocurrency) Although at this point in time, there are several very liquid exchanges within the United States, such as the one NYSE/ICE hosts (Coinbase).