For US cryptocurrency users, accounts with a non US exchange isn’t considered a foreign financial account at this time. As such, US cryptocurrency users do not have to file FinCEN Form 114 (also known as FBAR), to report activity on foreign cryptocurrency exchanges. However, legislation or administrative rulings in the future could require taxpayers to file this form. Similar to FBAR, the IRS has Form 8938 (also known as FATCA). As of right now, the IRS has not stated whether this form must be filed. Since FBAR is not required at this time, you may not have to file FATCA.