If you are a US green card holder, the IRS treats you as a US tax resident from the day you get the card — which means your Nigerian naira and domiciliary accounts are "foreign financial accounts" that must be reported once your combined foreign balances cross $10,000 at any point in the year (FBAR), or a higher threshold that depends on where you live (FATCA). Merely having a Social Security Number does not, by itself, create this obligation — residency status does.
Green card = US tax resident = worldwide income and account reporting, full stop, regardless of where you actually live. This is the green card test, and it applies even if you moved back to Lagos the day after your card was approved and never touched US soil again (FBAR Green Card Holders: What Permanent Residents Must Know, FATCA Reporting for Green Card Holders). There is no US–Nigeria tax treaty to soften this, and no exception for accounts held in naira rather than dollars — currency doesn't matter, control and ownership do.
The IRS and FinCEN definitions are broad on purpose. A reportable foreign financial account includes:
- Naira savings and current accounts at GTBank, Zenith, Access, UBA, or any other Nigerian bank
- Domiciliary (USD, GBP, or EUR) accounts held at a Nigerian bank
- Fixed deposits and money market accounts
- Mutual funds, pension contributions, and most investment accounts held through a Nigerian institution
- Any account where you have signature authority, even if the money isn't yours (e.g., a joint account with a parent, or one you manage for a family business)
The test is location of the institution, not the currency inside the account. A ₦2 million savings account and a $15,000 domiciliary account at the same bank are both "foreign" for these purposes (IRS: Report of Foreign Bank and Financial Accounts).
FBAR is not a tax return — it's an information report filed with FinCEN, not the IRS itself, via the BSA E-Filing system. You must file it if the aggregate value of all your foreign financial accounts exceeded $10,000 at any single point during the calendar year — not on average, not at year-end, but at the single highest moment. Add up every account you hold or control: one ₦3 million account plus one $8,000 domiciliary account can easily clear $10,000 combined even though neither account alone looks large.
The FBAR deadline tracks the tax filing deadline (April 15), with an automatic extension to October 15 — no separate extension request needed.
FATCA is a separate, tax-return-attached requirement (Form 8938, filed with your Form 1040) with materially higher thresholds than FBAR, and the number that applies depends on your filing status and where you live:
- Living in the US, single: over $50,000 at year-end or $75,000 at any point
- Living in the US, married filing jointly: over $100,000 at year-end or $150,000 at any point
- Living abroad and meeting the physical-presence test, single: over $200,000 at year-end or $300,000 at any point
- Living abroad, married filing jointly: over $400,000 at year-end or $600,000 at any point
It is entirely possible to owe an FBAR filing without owing a Form 8938 — most green card holders with modest naira and domiciliary balances will fall into exactly this gap: over $10,000, under the FATCA threshold (IRS: Summary of FATCA Reporting for US Taxpayers).
No — and this is the most common confusion. An SSN by itself just proves you were authorized to work in the US at some point (OPT, H-1B, a prior visa). It does not automatically make you a US tax resident. What actually triggers FBAR/FATCA obligations is meeting either:
- The green card test — you hold a green card, full stop, even one day of the year.
- The substantial presence test — a day-counting formula based on time physically spent in the US over the current and prior two years.
Someone who held an SSN years ago on an F-1 visa, left the US, and let their status lapse is generally not a US tax resident and doesn't owe FBAR/FATCA today. Someone who still holds the green card, even while living full-time in Lagos, is — this distinction is exactly the kind of detail worth confirming with a CPA rather than assuming from the brief you got before relocating (US Tax Obligations Before Relocating: What Nigerian Professionals Must Know).
Many countries have signed intergovernmental agreements (IGAs) that let their banks report US-linked accounts automatically to their own tax authority, which then forwards the data to the IRS. Nigeria does not currently appear on the IRS's published list of jurisdictions with a FATCA IGA in effect (IRS: FATCA Governments). In practice, this doesn't remove your obligation to report — it shifts the compliance burden differently: Nigerian banks that want to keep serving US-linked customers must register directly with the IRS as Foreign Financial Institutions and report account information themselves, rather than routing it through a Nigerian regulator. Either way, the IRS's visibility into Nigerian accounts held by US persons has been steadily improving, not disappearing.
The numbers escalate quickly. For 2026, non-willful FBAR violations can draw penalties up to $16,536 per account, per year; willful violations reach the greater of $165,353 or 50% of the account balance. Missing a required Form 8938 draws a $10,000 penalty, rising by $10,000 for each 30 days of continued non-filing after an IRS notice, up to $50,000 (FBAR Penalties 2026: Amounts & Relief Options).
If you've been a green card holder for years and never filed, the IRS's Streamlined Filing Compliance Procedures exist precisely for this situation — non-willful non-compliance (oversight or misunderstanding, not intentional evasion) can be resolved by filing the 3 most recent delinquent tax years and 6 most recent delinquent FBARs. Filers living abroad who qualify under the Streamlined Foreign Offshore Procedures pay zero penalty; those still residing in the US pay a one-time 5% miscellaneous offshore penalty under the domestic version. The critical constraint: this door closes the moment the IRS has already contacted you, so acting proactively matters more than acting perfectly (The Streamlined Filing Compliance Procedures).
- List every Nigerian account you hold or have signature authority over — naira, domiciliary, fixed deposit, pension.
- Pull the highest balance each account touched during the year, converted to USD at the relevant date's exchange rate.
- Add them up. If the combined peak exceeded $10,000, you owe an FBAR.
- Check your filing status and residency (in the US vs. abroad) against the FATCA thresholds above to see if Form 8938 also applies.
- If you've missed prior years, talk to a CPA or tax attorney who handles cross-border filings before doing anything else — streamlined procedures are unforgiving of DIY mistakes.
The hardest part of this exercise is rarely the tax rule — it's reconstructing the peak balance across a naira account, a domiciliary account, and maybe a fixed deposit, each quoted in a different currency, at a different bank, on a different statement. Kampe is built for exactly that view: it's a read-only tool that pulls your Nigerian accounts together and shows one honest number, in one currency, so you can see at a glance whether your combined foreign balances are anywhere near the $10,000 FBAR line before your accountant has to ask. It doesn't file anything or move your money — it just gives you the number you need before you talk to someone who does.