Aggregate threshold determination
All foreign financial accounts are aggregated; if the total exceeds $10,000 at any point during the calendar year, an FBAR is required. The engine verifies this deterministically.
The most rigorous FBAR/FATCA filing pack a firm can deliver.
Offshore Foreign-Asset Reporting Engine assembles a documentation-complete filing pack — every required form, every account's highest balance, Treasury conversion, aggregation against thresholds, and non-willful certification narrative — checked against the letter of 31 C.F.R. §1010.350 and IRC §6038D before a credentialed preparer releases it.
Every subsection of 31 C.F.R. §1010.350 and IRC §6038DMultilingual statement OCR in any languageTreasury year-end conversion rate appliedCredentialed preparer review on every pack5-business-day SLA
Why filings fail
A single missed account can trigger a $16,536 penalty.
Foreign-asset reporting is mandatory, annual, and severely penalized. Miss one account's highest balance, use the wrong conversion rate, or fail to aggregate correctly — and the filer faces a $16,536 non-willful penalty per form, or up to 50% of the account balance for willful failures.
Most firms gather statements by hand, from banks in a dozen countries, in multiple languages and currencies. The work is punishing and repetitive, and the compliance gap is enormous: only about 1.2 million FBARs are filed each year against an estimated 5.5–9 million U.S. persons abroad.
Offshore Foreign-Asset Reporting Engine exists to close that gap with a single, exhaustive standard applied identically to every file.
$16,536
maximum non-willful FBAR penalty per form (as of Jan 17, 2025)
The benchmark
Measured against the letter of the regulation — subsection by subsection.
We do not summarize the law and hope. Every pack is scored against a versioned rule pack tied to the exact text of 31 C.F.R. §1010.350 and IRC §6038D. These are the provisions each pack is held to.
Highest balance extraction
For each account, the single highest balance during the calendar year is identified from statements, not the year-end balance. The engine extracts this from multilingual statements.
Treasury year-end conversion
All foreign currency balances are converted to U.S. dollars using the Treasury's Financial Management Service year-end rate. The engine applies the correct rate per currency.
Form 8938 threshold and reporting
Specified foreign financial assets exceeding $50,000–$600,000 (depending on filing status) trigger Form 8938. The engine aggregates and compares against the applicable threshold.
Signature and certification
Each FBAR must be signed and certified. The engine drafts the non-willful certification narrative; a credentialed preparer reviews and signs.
Streamlined catch-up package
For eligible non-willful filers, the engine assembles the three most recent FBARs, Form 8938s, amended returns, and the required certification statement — all checked against the Streamlined procedures.
How a pack is built
Intake to credentialed release, with deterministic gates the AI cannot overrule.
AI extracts and drafts. Deterministic rules — running as code, outside the model — decide what is complete. A credentialed preparer signs every release. That order is never reversed.
01
Free Exposure Scan
Upload one year of foreign account statements. We return a free filing-requirement determination and a penalty-exposure estimate — no commitment.
02
Statement ingestion & extraction
Our AI reads statements in any language and currency, extracts each account's highest daily balance, and identifies account types and ownership.
03
Conversion & aggregation
Balances are converted at the Treasury year-end rate and aggregated against the $10,000 FBAR and $50,000–$600,000 Form 8938 thresholds.
04
Deterministic completeness gates
All accounts are accounted for; thresholds are verified; conversion rates are checked; the non-willful narrative is drafted. Any failure blocks release.
05
Credentialed preparer review
A CPA/EA or attorney reviews the exception queue and signs the pack. High-value or complex entity accounts route to senior review.
06
Delivery
You receive the filed forms (FBAR, Form 8938, Streamlined package), workpaper trail, and certification narrative — ready for the firm to deliver to the client.
The bar we hold
Rigor you can measure.
100%
Credentialed-preparer released
No pack ships without a human signature.
5 days
Standard SLA
From complete intake to released pack.
<1%
Critical-defect target
Tracked against a gold-standard pack library.
4
Lien-search sources
DHSMV · USCG · UCC · judgment, every applicable file.
Why Offshore Foreign-Asset Reporting Engine
Built to be the most thorough option a firm has.
Documentation-complete, by design
The deliverable is completeness itself — every account, every balance, every conversion accounted for or explicitly exception-coded. Nothing is left implicit.
Deterministic, not vibes
The gates that decide completeness are code, not a model's opinion. A drafting error cannot slip past a regulatory requirement.
In its lane, on purpose
We prepare documentation and run searches as your clerical agent. We never contact the taxpayer, give legal advice, or file without a credentialed signature.
Engagement
Flat fee, per filing. No hourly billing, ever.
Simple, predictable, and aligned with a documentation standard — not a cut of any penalty savings.
- A free Exposure Scan before you commit — see exactly what is missing.
- One flat fee per FBAR, per Form 8938, and per Streamlined package; disclosed pass-through search fees.
- Optional fixed-fee attorney review for complex entity accounts or willful determinations.
- Optional multi-year catch-up add-on for Streamlined packages covering up to six years.
FAQ
Questions, answered precisely.
Is Offshore Foreign-Asset Reporting Engine a law firm or tax preparation firm?
No. Offshore Foreign-Asset Reporting Engine, a service of Your Deputy, Obuke LLC, provides documentation-completeness services. It is not a law firm, does not provide legal advice, and does not represent you before the IRS. A credentialed preparer (CPA/EA/attorney) reviews and signs every pack.
Do you contact the taxpayer or file directly with the IRS?
Never. We prepare the documentation as your clerical agent. The firm remains the preparer of record and is responsible for filing and delivering all forms to the client.
What makes a pack 'complete'?
Completeness is defined by the regulations: all accounts aggregated, highest balances extracted, Treasury conversion applied, thresholds verified, and non-willful certification drafted. Deterministic gates enforce each one before release.
How fast is it?
The standard SLA is five business days from complete intake to a credentialed-preparer released pack. The free Exposure Scan is returned much sooner and tells you exactly what is still needed.
How are you priced?
A flat fee per filing (per FBAR, per Form 8938, per Streamlined package), plus disclosed pass-through costs. No hourly billing and no percentage of any penalty savings.
See what's missing before it costs you a penalty.
Start with a free Exposure Scan. Upload one year of foreign account statements and we'll return a filing-requirement determination and a penalty-exposure estimate against every subsection of 31 C.F.R. §1010.350 and IRC §6038D.
Documentation-completeness service · not legal or tax advice · the firm files every form.