Hipster also has an account at a crypto exchange based outside the US, holding nothing but digital assets. No dollars, no local currency, just crypto. It's the account he worried about most, and the one with the least settled answer.
FinCEN is unusually direct here. In Notice 2020-2 it said: "a foreign account holding virtual currency is not reportable on the FBAR (unless it is a reportable account under 31 C.F.R. 1010.350 because it holds reportable assets besides virtual currency)." It also said it intends to propose amending the regulations to add virtual currency as a reportable account type. As of October 2026, there is no final rule, and FinCEN's regulatory agenda entry for FBAR amendments (RIN 1506-AB26) doesn't mention virtual currency.
So today, crypto-only means not reportable. Two catches. First, that answer rests on a 2020 notice about a rule FinCEN plans to change, with no promised timing or transition. Second, the exception covers only accounts holding nothing but virtual currency. Add a cash balance or any other reportable asset and the whole account is reportable, like any other foreign account.
A general-audience book shouldn't settle this. It turns on exactly what the account holds and the state of the rulemaking on the due date.