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The short answer
You must file an FBAR if the combined value of all your foreign financial accounts was more than $10,000 at any time in the calendar year. With several Nigerian accounts you add up each account's maximum value, converted at the Treasury rate for the last day of the year; if the total passes $10,000, you report every account, including small and dormant ones.
The test in the rules
The IRS FBAR page (reviewed July 2026) says US persons must file FinCEN Form 114 if the combined value of their foreign financial accounts exceeded $10,000 at any time during the calendar year. FinCEN's filing instructions use the same wording: file if "the aggregate value of the foreign financial accounts exceeds $10,000 at any time during the calendar year". It does not matter whether the accounts earn taxable income.
Accounts counted include savings, current, domiciliary, fixed deposit and brokerage accounts at Nigerian banks and other financial institutions, plus accounts you have signature authority over. Our guide to whether you must file an FBAR for Nigerian bank accounts covers who counts as a US person.
How to add the accounts
- Find each account's maximum value. FinCEN defines it as "a reasonable approximation of the greatest value" during the year. Periodic statements are usually enough.
- Convert each to dollars. Use the Treasury's reporting rate for the last day of the calendar year, as the instructions require, even for a peak in March. If none is available, use another verifiable rate and state the source.
- Round up and treat negatives as zero. Amounts are rounded up to the next whole dollar; an overdrawn account counts as zero.
- Add the maximum values. If the total is over $10,000, you file and list every account.
Adding maximums can push you over $10,000 even if the accounts never held that much on the same day, because their peaks fall at different times. That is the method the form follows, so check with a preparer before relying on any other reading.
A worked example
Example only. The rate is illustrative; check the Treasury rate for the year you are reporting. Funmi, in Houston, has three Nigerian accounts. Using an illustrative year-end rate of ₦1,500 = $1:
| Account | Highest balance in year | In dollars |
|---|---|---|
| Naira savings, Lagos | ₦6,000,000 (April, rent received) | $4,000 |
| Naira current account | ₦4,500,000 (December) | $3,000 |
| Domiciliary (USD) account | $3,500 (August) | $3,500 |
| Total of maximums | $10,500 |
Check: 6,000,000 ÷ 1,500 = 4,000; 4,500,000 ÷ 1,500 = 3,000; $4,000 + $3,000 + $3,500 = $10,500. No single account was near $10,000, but the total of maximum values is over the line, so Funmi files and reports all three. If she also had an old account holding ₦30,000, she would list it too.
Common mistakes with several accounts
- Counting only big accounts. Once the total passes $10,000, every account is reported.
- Using year-end balances. The test uses the highest value during the year, not the 31 December balance.
- Using a remittance app's rate. FBAR uses the Treasury reporting rate, not the rate you sent money at. See which exchange rate to use for naira.
- Leaving out joint or signatory accounts. Each joint owner reports the entire value of a joint account, and accounts you can sign on count too. See FBAR for an account shared with a parent.
- Forgetting Schedule B. If you have a foreign account, Schedule B asks the question on line 7a, and the instructions say answer "Yes" even if you are not required to file an FBAR.
What counts towards the $10,000, and what does not
FinCEN's instructions list the kinds of account that count: savings, demand, checking, deposit and time deposit accounts, securities and brokerage accounts, cash-value insurance or annuity policies, and shares in mutual or similar pooled funds, all held at a financial institution outside the US. A Nigerian fixed deposit, a domiciliary account and an investment account with a Lagos stockbroker all fall within that list.
- Excluded: the IRS FBAR page names accounts at US military banking facilities, IRAs you own or benefit from, and accounts held in a retirement plan of which you are a participant or beneficiary.
- Not accounts at all: naira notes kept at home, a plot of land or a house. These are not financial accounts, so they do not count towards the test.
- Uncertain: neither the IRS FBAR page nor FinCEN's instructions mention Nigerian retirement savings accounts (RSAs) by name. Ask a preparer before leaving one out.
The FBAR is separate from Form 8938, which has much higher thresholds. The IRS comparison chart (September 2026) sets Form 8938 for a single filer living in the US at more than $50,000 on the last day of the year or more than $75,000 at any time, so many people with several Nigerian accounts file an FBAR but not Form 8938. See Form 8938 thresholds for married couples.
Filing and deadlines
The FBAR is filed electronically through FinCEN's BSA E-Filing System, not with your tax return. It is due on 15 April with an automatic extension to 15 October. Records must be kept for five years. If you hold 25 or more accounts, the instructions let you skip the account-by-account detail on the form but you must keep the records. This is general information, not tax advice.
Where Pryme fits
If you hold naira through Pryme, those deposits are held by a licensed Nigerian microfinance bank, so treat them like any Nigerian account when you work out this test, and confirm the reporting with your preparer. Pryme customers can download a statement showing balances through the year, which helps you find each maximum, and hold several currencies in one account instead of spreading money across many.
Questions people ask
Do I add all my Nigerian accounts together for the FBAR?
Yes. The test is whether the aggregate value of all foreign accounts exceeded $10,000 at any time in the year. Add each account's maximum value.
If my total is over $10,000, do I report small accounts?
Yes. Once the threshold is passed, every foreign account is reported, however small.
Which exchange rate do I use for FBAR naira balances?
FinCEN's instructions say to use the Treasury reporting rate for the last day of the calendar year, or another verifiable rate with its source if none exists.
Is a negative balance counted for FBAR?
No. The instructions say a negative value is entered as zero.
Sources
- IRS: Report of Foreign Bank and Financial Accounts (FBAR) (reviewed 30 Jul 2026) · accessed Oct 2026
- FinCEN: BSA E-Filing FBAR line item filing instructions · accessed Oct 2026
- IRS: Instructions for Schedule B (reviewed 30 Apr 2026) · accessed Oct 2026
- IRS: Comparison of Form 8938 and FBAR requirements (reviewed 19 Sep 2026) · accessed Oct 2026
This article is general information, not financial, legal or tax advice. Products described are provided under the terms on this site and are subject to regulation and eligibility.