IRS Tightens the Screws on Foreign Account Reporting
The US Internal Revenue Service (IRS) has significantly stepped up its enforcement around foreign bank account reporting in 2025, putting many unsuspecting US expats in the UK under increased scrutiny. With growing data-sharing agreements and more sophisticated audit tools, those who hold accounts in the UK or offshore jurisdictions must now tread carefully or risk severe financial penalties.
If you’re a US citizen or green card holder residing in the UK, the chances are high that you fall under the reporting obligations for FBAR (Foreign Bank Account Report) and FATCA (Foreign Account Tax Compliance Act). Even if you haven’t lived in the US for years, your global financial footprint remains of interest to the IRS. In fact, many dual residents are unaware that holding more than $10,000 across one or multiple non-US accounts triggers a mandatory FBAR filing — a rule that hasn’t changed but is now being enforced more aggressively.
The penalties for failing to file FBARs can be staggering. In 2025, fines range from $10,000 per unreported account for non-willful violations, to up to 50% of the account balance for willful non-compliance. These are not theoretical risks — the IRS has already launched high-profile enforcement campaigns in partnership with HMRC and European tax authorities to identify underreporting.
At Xerxes Associates LLP, we’ve seen a notable uptick in enquiries from US-connected individuals caught off guard by these requirements. Many assumed that keeping money in UK ISAs, investment portfolios, or even basic current accounts didn’t fall under the FBAR or FATCA radar — but they do. The IRS requires detailed reporting, not only of bank balances but also of account ownership, access rights, and financial interests in trusts and foreign entities.
FATCA, meanwhile, brings a separate but related layer of complexity. Most US expats must file Form 8938, which covers broader financial assets than FBAR and has different thresholds depending on marital status and residence. While FBAR is submitted to FinCEN, Form 8938 is attached to your federal tax return — and failure to file can lead to an additional $10,000 penalty plus interest and potential audits.
2025 also marks a renewed focus by the IRS on compliance gaps in high-value jurisdictions like London, Zurich, and Singapore. Automated data exchanges under FATCA and CRS (Common Reporting Standard) mean that even previously undisclosed accounts are now easily traceable. Financial institutions are obliged to report directly to the IRS, leaving little room for error or omission.
If you’re unsure whether you’ve filed the correct forms or whether you’ve been compliant in recent years, it’s not too late. Xerxes Associates LLP offers confidential reviews and helps clients enter the IRS Streamlined Filing Compliance Procedures — a penalty-free amnesty program for non-willful offenders. We also assist in reconstructing past years’ reports, communicating with both the IRS and HMRC, and protecting clients from avoidable penalties.
The bottom line is simple: FBAR and FATCA compliance is no longer optional or low-risk. As an American abroad, your financial activities in the UK and beyond are reportable under US law, and 2025 is the year the IRS is proving it means business. Let Xerxes Associates LLP help you bring clarity and confidence to your compliance.
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For those seeking guidance on taxation or other expatriate tax matters, Xerxes Associates LLP offers consultations to discuss individual needs and circumstances. To learn more about their services or to schedule a consultation, visit their contact page.
