Updated 24 October 2026
Wise and Revolut are where a lot of Americans abroad keep their everyday money, so the FBAR question comes up every spring. The honest short answer: FinCEN and the IRS describe a test based on where an account is located, the two companies hold accounts through different legal entities depending on where the customer lives, and neither FinCEN nor the IRS has published guidance that names either company. This guide sets out those three things so you can take them to whoever prepares your FBAR.
What makes an account foreign for the FBAR
FinCEN defines a foreign financial account as "a financial account located outside of the United States". Its own examples show that the bank's nationality doesn't decide it: an account at a US bank's branch abroad is foreign, and an account at a foreign bank's branch in the United States is not.1 IRS Publication 5569 puts it in one line: "It is the location of the account, not the nationality of the financial institution, that determines whether an account is 'foreign' for FBAR purposes."2
The definition of a financial account is broad. FinCEN's list ends with "other account maintained with a financial institution (or other person performing the services of a financial institution)",1 and the regulation's "other financial account" includes an account with a person "in the business of accepting deposits as a financial agency".3
What none of these sources does is name Wise, Revolut, e-money or payment institutions. We searched FinCEN's FBAR guidance, Publication 5569, the Internal Revenue Manual and the regulation and found nothing that applies the test to either company. Currency isn't part of the test either: it asks where the account is, not what it holds.
Which Wise company holds your account
Wise publishes a table of which company holds your money, by where you live and which currency.4 Its US customer agreement is a contract with Wise US Inc.5
| Customer | Wise company, per Wise |
|---|---|
| US customers | Wise US Inc., a Delaware company with its office in New York, licensed as a money transmitter. In American Samoa, the Mariana Islands and Nevada, Wise publishes a separate agreement, with Community Federal Savings Bank5 |
| EEA residents | Wise Europe SA, incorporated in Belgium, for all currencies except BRL, CNY, TRY, INR, MYR and MXN4 |
| UK and other non-EEA residents (GBP, USD, CHF, NZD, HKD, and EUR and other European currencies) | Wise Payments Ltd, incorporated in the United Kingdom4 |
| Residents of Canada, Australia, Japan, Singapore and some other countries | A local company, such as Wise Payments Canada Inc. or Wise Australia Pty Ltd4 |
Three details from Wise's own agreements are worth having in front of you:
- The US agreement says incoming payments are credited to "your Wise Account that is held at the Wise entity described in the beginning of this Agreement (regardless of currency)". So a euro balance in a US Wise account is, in Wise's words, held at Wise US Inc.5
- The same agreement says "Wise is Not a Bank, and your Wise Account is Not a Bank Account."5
- Wise Europe SA describes itself as a Belgian company authorised by the National Bank of Belgium, and the money in its Wise Accounts as issued under Belgium's law on payment and electronic money institutions.6
Some currencies, such as the Brazilian real, sit with a different entity whatever your residence, so check the table for each balance you hold.4
Which Revolut company holds your account
Revolut says the company that serves you "depends on where you're located".7 Its published terms name these:
| Customer | Revolut company, per Revolut |
|---|---|
| US customers | Revolut Technologies Inc. runs the account; the funds are held by Lead Bank, an FDIC member8 |
| EEA personal customers | Revolut Bank UAB, a bank licensed in Lithuania (for customers in Ireland, acting through its Irish branch)9 |
| UK customers | Revolut Ltd, authorised by the FCA to issue e-money10 |
Revolut's EEA terms describe Revolut Bank UAB as "licensed and regulated by the Bank of Lithuania and the European Central Bank as a credit institution".9 Its UK terms describe the account as "a 'virtual' account that holds your e-money", which "may hold e-money in different currencies at the same time".10 Revolut's UK help pages also name a separate bank, Revolut Bank UK Ltd, authorised by the Prudential Regulation Authority.11 Which company holds a UK account can change, so read the terms you're on now rather than relying on this table.
What this does and doesn't settle
Put the pieces together and you have what the providers publish about themselves: Wise Europe SA, Wise Payments Ltd, Revolut Bank UAB and Revolut Ltd are companies based outside the United States, while Wise US Inc., Revolut Technologies Inc. and Lead Bank are US companies. What you don't have is any FinCEN or IRS statement that applies the location test to these providers, says where an account held by one of them is located, or explains how e-money accounts fit the definition of a financial account. Those are judgment calls for you and your tax professional, and this guide doesn't make them for you.
One account, several currencies
FinCEN's steps assume each account has one currency: find "the maximum value of each account (in the currency of that account)", and value each account separately.1 A Wise or Revolut account can hold several currency balances at once. We found no FinCEN or IRS guidance on whether each balance is a separate account for the FBAR or how to value them together. Ask your preparer how they want them treated before you start adding numbers up.
Finding the yearly maximum
FinCEN asks for "a reasonable approximation of the greatest value" in the account during the calendar year, and lets you rely on periodic statements that fairly reflect the maximum.1 Publication 5569 describes those as statements issued at least quarterly.2 Neither provider fits that neatly:
- Wise (US): the agreement says "Wise does not furnish periodic statements", but keeps an electronic history of at least 12 months in the app and website, and a written history of at least 24 months on request.5 Wise's help centre explains how to download statements for up to 365 days at a time, on the web as PDF, XLSX, CSV and other formats.12
- Revolut: statements are generated per currency account, for a timeframe you choose, as PDF or Excel, and include a balance summary.11
Download the full calendar year for each balance and look for the highest figure in that balance's own currency. Then convert it at the Treasury's rate for 31 December, which the FBAR calculator does for any value you type, rounding up the way FinCEN asks. The maximum account value guide covers the steps in detail, and the exchange rates guide has the year-end tables.
What to bring to your preparer
- The customer agreement for each Wise or Revolut account, showing which company it's with.
- A full-year statement or export for every currency balance.
- The highest balance in each currency, with its date.
- Whether anyone else owns or can sign on the account.
For how the FBAR compares with Form 8938, see FBAR and FATCA explained.