The IRS and FinCen have not given a lot of clarity on the “official” rules for reporting (or not) virtual currency holdings on your FBAR, but here are some general guidelines:
1) If you store your virtual currency on a public exchange (e.g. Coinbase, Kraken), and the account is located in the US, you DO NOT need to include this account on your FBAR.
2) If you store your virtual currency on a public exchange (e.g. Binance), and the account is located outside of the US, you DO need to include this account on your FBAR.
3) If you hold your virtual currency in a private wallet with a private key (i.e. not on an exchange like Coinbase), this is considered equivalent to cash and DOES NOT need to be reported on your FBAR.
Note: If you are not sure where your public exchange is located there is a pretty good list (and some more detailed general info) in this article: https://tokentax.co/help/do-you-need-an-fbar-for-crypto/
If you have any doubt at all, it is better to include an account unnecessarily on your FBAR (no penalties for this) than to leave one off that should be included (potential $10,000 penalty per account even if “non-willful” non-reporting).
