AI agents for business finance: what they can and can't do
What AI agents can do in bookkeeping, close, collections and compliance today, where a person must stay in charge, and how to judge a product.
The short answer
A US company files an FBAR (FinCEN Form 114) if it has a financial interest in, or signature authority over, foreign accounts whose combined value exceeded $10,000 at any time in the calendar year. That includes accounts held by a Nigerian subsidiary it owns more than 50% of. The FBAR is due 15 April with an automatic extension to 15 October and is filed through FinCEN's BSA E-Filing System, not with the tax return.
The FBAR is often thought of as a personal filing for people with savings abroad, but it applies to US entities too. A US corporation or LLC with a naira account in Lagos, or with a Nigerian subsidiary that has its own bank accounts, can be inside the rules, and so can the individuals who sign on those accounts. This guide covers the company's side; the individual signatory's side has its own guide. It is information, not legal or tax advice.
Who files
The IRS FBAR page (reviewed 30 July 2026) says US persons must file, and lists citizens, residents, corporations, partnerships, LLCs, trusts and estates. A US person files if it has a financial interest in, or signature or other authority over, foreign financial accounts whose aggregate value exceeded $10,000 at any time during the calendar year. The IRS comparison page adds that the account counts whether or not it produces taxable income.
Financial interest through a subsidiary
Publication 5569, the IRS FBAR Reference Guide (Rev. 3-2022), says a US person has a financial interest in an account where the owner of record is a corporation in which the US person owns, directly or indirectly, more than 50% of the total value of shares or more than 50% of the voting power. So a US parent owning, say, 100% of a Nigerian company has a financial interest in each of that company's Nigerian bank accounts, even though the parent's name is not on them.
Consolidated FBAR
Publication 5569 also says a US entity named in a consolidated FBAR filed by a greater-than-50% owner does not need to file separately. A US parent can file one consolidated FBAR covering its own foreign accounts and those of US subsidiaries it owns more than 50% of.
Measuring the $10,000
The test is aggregate maximum value across all foreign accounts at any time in the year, not the year-end balance. FinCEN's filing instructions describe maximum value as a reasonable approximation of the greatest value during the year and say to convert at the Treasury's rate for the last day of the calendar year.
A worked example
Example rates only. A US company's wholly owned Lagos subsidiary has two naira accounts. Account A peaked at ₦9,000,000 in March; Account B peaked at ₦7,500,000 in October. Using an example Treasury year-end rate of ₦1,500 per dollar, Account A's maximum is $6,000 and Account B's is $5,000. Neither alone exceeds $10,000, but the aggregate, $11,000, does, so the parent files and reports both accounts. Check: 9,000,000 divided by 1,500 is 6,000; 7,500,000 divided by 1,500 is 5,000.
Look up the Treasury reporting rate for naira for the last day of the year before you rely on any figure, and record where you found it. If the naira rate you find looks stale or is missing, ask your preparer what to use and note the reason in your file.
Deadline and filing
- Due 15 April following the calendar year, with an automatic extension to 15 October; no request is needed.
- Filed electronically through FinCEN's BSA E-Filing System, separately from the tax return.
- A filer with a financial interest in 25 or more foreign accounts ticks the box for that in Part I, item 14a, and keeps the account details instead of listing them, per Publication 5569.
Records and penalties
For each reported account, keep the account name, number, the bank's name and address, the account type and the maximum value, for five years from the FBAR due date. Publication 5569 says civil penalties for non-wilful violations run up to the amount in 31 CFR 1010.821, adjusted each year for inflation, and for wilful violations up to the greater of that amount or 50% of the account balance at the time of the violation. Criminal penalties can also apply.
Common mistakes
- Using the year-end balance instead of the highest balance during the year.
- Leaving out a dormant account, or one closed during the year; the test covers any time in the calendar year.
- Forgetting a subsidiary's accounts because the parent's name is not on them.
- Treating a dollar domiciliary account in Lagos as a US account; it is held at a financial institution outside the US.
- Assuming the company's filing covers its individual signatories.
What to check first
- List every foreign account of the company and of subsidiaries it owns more than 50% of.
- Find the maximum balance of each during the year from statements.
- Convert at the Treasury year-end rate and add them up.
- Decide whether to file a consolidated FBAR.
- List every US-person signatory; they may need their own filing.
The company will also file Form 5471 for a controlled Nigerian subsidiary; see transfer pricing between a US company and its Nigerian subsidiary. For signatories, see signature authority over a Nigerian business account.
Where Pryme fits
Naira balances in a Pryme account are held by a licensed Nigerian microfinance bank, so ask your preparer how to report them alongside your other Nigerian accounts. Statements from a Business Account, available as verifiable documents through VerifyDoc.ai, make the maximum-value exercise easier to support, and the Compliance agent can track the 15 April and 15 October dates you set.
Questions people ask
Does a US LLC need to file an FBAR for a Nigerian bank account?
Yes, if the LLC's foreign accounts together exceeded $10,000 at any time in the year. The IRS lists LLCs among US persons who must file.
Does the US parent report its Nigerian subsidiary's bank accounts?
If it owns more than 50% of the subsidiary by vote or value, Publication 5569 treats it as having a financial interest in those accounts.
When is the FBAR due for a company?
15 April following the calendar year, with an automatic extension to 15 October, filed through FinCEN's BSA E-Filing System.
Which exchange rate do I use for the FBAR?
FinCEN's instructions say to convert at the Treasury rate for the last day of the calendar year.
Sources
- IRS: Report of Foreign Bank and Financial Accounts (FBAR) (reviewed 30 Jul 2026) · accessed Oct 2026
- IRS: Publication 5569, FBAR Reference Guide (Rev. 3-2022) · 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.