US bank accounts: CRS, privacy and LLC reporting

Mercury, Wise US, Slash and Relay operate in the US/FATCA perimeter rather than the European CRS rail: privacy, KYC, documents and a coherent LLC file.

The United States has not joined CRS. FATCA follows a different architecture, and a US operating account held by your LLC does not become, by default, a European-style CRS feed to your home tax authority.

"Does Mercury tell my tax authority how much money I have?" This is the question we receive most often. Here's the complete, honest answer — no sugarcoating, no fear-mongering.

CRS 2.0, CARF and DAC8 for US bank accounts

The honest answer about what US banks report does not change with the OECD package: CRS 2.0 widens the perimeter outside the United States, but the domestic US banking system still does not operate as a CRS reporting institution because the United States is not, today, a CRS jurisdiction.

The OECD adopted an integrated package combining CRS 2.0 (the revised Common Reporting Standard, which brings EMIs and specified electronic-money products into the perimeter and tightens due diligence on controlling persons) and CARF (the Crypto-Asset Reporting Framework, which extends automatic exchange to crypto exchanges, custodians and crypto-derivative platforms). The European Union transposed it through Directive (EU) 2023/2226 (DAC8), adopted on 17 October 2023, which amends Directive 2011/16/EU to incorporate both components. The substantive application date is 1 January 2026 and the first effective exchange lands in January 2027 over the prior reporting period.

Official sources: <a href="https://www.oecd.org/tax/automatic-exchange/common-reporting-standard/" target="_blank" rel="noopener nofollow">OECD — CRS</a>, <a href="https://www.oecd.org/tax/exchange-of-tax-information/crypto-asset-reporting-framework-and-amendments-to-the-common-reporting-standard.htm" target="_blank" rel="noopener nofollow">OECD — CARF</a>, <a href="https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023L2226" target="_blank" rel="noopener nofollow">EUR-Lex — Directive (EU) 2023/2226 (DAC8)</a>.

US bank accounts should be discussed with precision: there is KYC, AML, bank recordkeeping, IRS/FinCEN reporting where applicable and legal cooperation mechanisms, but not the same CRS-style automatic exchange of every balance and movement common in many European contexts. Privacy is real when the structure is documented; it is not anonymity. We unpack the broader privacy layer in <a href="/en/blog/crs-carf-and-us-banking-privacy-for-llc-owners">CRS, CARF and US banking privacy for your LLC</a>.

The three mechanisms of international financial reporting

1. CRS (Common Reporting Standard): Automatic exchange between 100+ countries for non-resident accounts. The US is notably absent from CRS.

2. FATCA (Foreign Account Tax Compliance Act): US law requiring foreign financial institutions to report accounts of US citizens/residents to the <a href="https://www.irs.gov" target="_blank" rel="noopener">IRS</a>. The US has its own system separate from CRS.

3. Bilateral agreements (IGAs): Country-specific treaties for information exchange. The US has signed Intergovernmental Agreements with many countries under FATCA.

What happens with your Mercury account?

Mercury is a US fintech backed by US partner banks, including Choice Financial Group and Evolve Bank & Trust, with Column N.A. still present in some older infrastructure contexts. It operates within the US financial system, not the European CRS perimeter.

Does Mercury report to the IRS? It complies with the US banking and tax perimeter through its partner-bank infrastructure: KYC, AML, Bank Secrecy Act controls and informational reporting when a specific rule applies. That is not the same as an annual CRS export of balances, owners and movements to a foreign tax authority.

Does Mercury report to your home tax authority? Not directly through CRS (the US doesn't participate). However:

  • The US and your country may have a FATCA IGA allowing some reciprocal information sharing
  • Your country's tax authority can request information specifically through tax treaty mechanisms
  • Information exchange is possible but not automatic in the CRS sense

The practical reality: automatic reporting from US financial institutions to foreign tax authorities is materially narrower than CRS reporting from European institutions. That does not remove local filing obligations; it changes the automatic exposure surface.

What about Wise?

Wise is more complex. As an EMI with presence in multiple jurisdictions (UK, EU, US), Wise has CRS reporting obligations in CRS-participating countries.

Practical implication: If your Wise account is associated with a CRS-participating jurisdiction, your home country may receive annual summary information about your account.

What gets reported via CRS: Year-end balance, income generated (interest). NOT individual transactions.

And Relay?

Relay uses Thread Bank as its banking infrastructure. Similar to Mercury, it operates within the US system. Same situation as Mercury regarding reporting.

And Slash?

Slash is a treasury management platform. Its reporting obligations depend on the specific banking infrastructure it uses. Similar considerations as Mercury apply.

The Modelo 720 and similar obligations

Regardless of what gets automatically reported, most countries require you to declare foreign assets:

Spain: Modelo 720 for foreign assets exceeding €50,000. This is YOUR obligation, not the bank's. Non-compliance carries penalties. Exentax reviews the case before money, signatures or provider replies move forward.

Mexico: Informational declaration of foreign investments (SAT).

Colombia: Declaration of foreign assets (DIAN).

Argentina: Personal assets declaration including foreign assets (Bienes Personales).

The practical conclusion

  1. A US operating account is not a CRS account. That is a structural difference, not a marketing trick: the United States runs on its own FATCA, KYC, AML, Bank Secrecy Act and legal-access perimeter, and a US LLC account does not create an annual automatic feed of balances and movements to your home tax authority.
  1. You still file what your residence requires. Spain may require Modelo 720/721, France has its own foreign-account rules, and other countries have equivalents. The advantage is not omission; it is lower automatic exposure plus a cleaner operating perimeter.
  1. Traceability is the shield. Invoices, contracts, bank statements, W-8BEN-E, Form 5472/pro-forma 1120, distributions and accounting must form one coherent file.
  1. FBAR is not the default rule for a foreign owner. FBAR generally applies to US persons with foreign financial accounts. A non-resident owner of a US LLC does not become an FBAR filer just because the LLC has a US operating account. If there is a US person, US manager, US signature authority or a different fact pattern, it must be reviewed separately.

The Exentax approach is simple: use the US banking privacy perimeter aggressively, but with records. Privacy works best when the file is clean.

The trend toward more automatic reporting outside the US

The global direction outside the United States is unmistakable: more information exchange, not less. Consider:

  • CRS now covers 100+ jurisdictions: and more countries join each year
  • FATCA expanded: more countries signing bilateral IGAs
  • EU DAC7/DAC8: platform reporting for digital economy
  • <a href="https://www.oecd.org" target="_blank" rel="noopener">OECD</a> CARF: expanding crypto-asset reporting globally
  • Beneficial ownership registries: broader company-control reporting in many jurisdictions; in the US, FinCEN narrowed federal BOI reporting for US-formed companies under the March 2025 interim final rule

That is exactly why the US perimeter matters. Many European fintech, EMI, broker and crypto rails are moving toward more automatic disclosure. A properly structured US LLC account is different: documented, regulated and traceable, but not CRS-native.

What this means for your strategy

  1. Transparency is your friend. A well-documented LLC with proper compliance is bulletproof under any reporting regime
  2. Don't structure around information gaps. Today's gap is tomorrow's exchange mechanism
  3. Proper deductions save more than hiding income. Legitimate expense deductions through your LLC save you far more than any reporting gap could

The LLC advantage isn't secrecy — it's efficiency. You pay less because your structure is more efficient, not because nobody knows about it.

One adjacent read worth having open alongside this one: <a href="/en/blog/real-tax-savings-for-international-freelancers">Optimal tax structure for international freelancers: the complete framework</a>, which sharpens exactly the edges we skimmed above.

The useful question is not whether a US account is visible or invisible. The useful question is which reporting channel applies, what the bank actually knows, what your residence country requires from you and whether your LLC records can explain every relevant movement.

US financial privacy: real privacy, regulated access

The United States does have real financial privacy. Not as offshore folklore, but as a legal and banking architecture. Banks know the customer, identify beneficial owners, apply KYC/AML and Bank Secrecy Act controls, keep records and report when the law requires it. The difference is that a US corporate account is not built around the CRS model of sending year-end balances, account holders and financial income automatically to a foreign tax authority.

That distinction is exactly why the structure matters. The account is traceable, but it is not automatically exposed through CRS. Access to specific financial records normally requires a proper legal channel, a concrete basis and cooperation under the applicable procedure. That is privacy with rules, not opacity.

For an LLC, this is commercially powerful when the file is clean: separate corporate banking, contracts, invoices, W-8BEN-E, Form 5472/pro-forma 1120, accounting and planned distributions. The point is not to hide the company; the point is to operate from a jurisdiction whose banking privacy and reporting framework are different from the European CRS perimeter.

From worry to operating map

The useful map has four fields: account jurisdiction, account holder, beneficial-owner residency and applicable reporting framework. For a US LLC operating account, that map usually points to US KYC/AML/FATCA and formal legal-access channels, not to a CRS annual file. If one of those fields changes — European IBAN, personal account, European broker, crypto platform, local distribution — the answer changes with it.

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The reporting rules behind US bank accounts

US banking privacy only has value when the LLC, owner residence, account purpose, retained funds and reporting duties are documented. It is a different reporting perimeter, not a substitute for a tax file.

_More on this topic: LLC in the United States: complete guide for non-residents._

What can actually cross from the US to your tax authority

The serious answer is not "US banks report nothing". The serious answer separates channels:

  1. CRS: US banks and US financial institutions are not CRS participants. Mercury, Relay, Slash and the US side of Wise Business do not send an automatic CRS file to your residence country.
  2. FATCA and IGAs: FATCA was built around US persons with accounts outside the US. Reciprocal exchange toward countries such as Spain exists, but it is narrower and does not equal the multilateral CRS flow for a non-resident LLC operating account.
  3. Formal requests: a tax authority can request specific information through a treaty, administrative assistance or a motivated procedure. It is not mass automatic reporting, but it exists, so the file must be clean.
  4. Your own filings and local bank trail: when you distribute funds to a personal account or exceed local reporting thresholds, the obligation comes from your tax residency, not from whether a US bank sends an XML file.

How to prepare without surprises

Keep the W-8BEN-E aligned with the real structure, invoice from the LLC, archive monthly statements, document member draws and review Modelo 720/721 or local equivalents when needed. The advantage is not omission; it is a US architecture that is orderly, traceable and defendable.

What Exentax coordinates in the banking file

Exentax connects the legal entity, beneficial-owner information, account purpose, expected flows and supporting tax documents before the banking stack is treated as complete. The working file records which provider holds each balance, which currency is used, how customer receipts arrive, how expenses and distributions leave, and which evidence should be retained. This gives the owner one coherent operating map for banks, payment platforms and annual compliance instead of separate explanations prepared after each request.

Questions to resolve before choosing a banking perimeter

Does a US LLC account create an automatic CRS report to my residence country? A US account held by the LLC through a US financial institution is assessed under the US provider and account-holder reporting perimeter rather than as a European CRS account, because the United States does not participate in CRS. That does not make the account invisible: the institution still performs KYC, identifies beneficial owners, keeps records and responds through applicable US reporting or lawful information-request channels.

Is Wise Business always treated like a US bank account? No. The contracting entity and account details matter. A US account provided through the US side of Wise is not the same product as an account or IBAN issued by a European Wise entity. Exentax records the legal provider, account jurisdiction and currency rail separately so the client does not use the brand name as a substitute for the reporting analysis.

Can the owner ignore local foreign-account filings because the bank does not use CRS? No. Local obligations arise from the owner's tax residence, the account holder, ownership or control, the type of asset and applicable thresholds. The absence of a CRS feed changes the automatic reporting channel; it does not cancel a filing that local law independently requires.

What documents should support the account? At minimum, the formation record, EIN evidence, Operating Agreement, current ownership information, business description, customer contracts, invoices, statements, accounting records and evidence for contributions or distributions should tell one consistent story. The exact file grows with the activity, provider and volume.

What happens when funds move to a personal account? The movement needs a documented character, such as a member distribution, reimbursement or another properly supported transaction. Moving funds without a clear basis weakens the separation between owner and company and makes both banking review and local tax reporting harder to explain.

How does Exentax use the US privacy perimeter? We design the entity, account map, documentation and reporting calendar together. The commercial advantage comes from operating through a regulated US structure with less automatic CRS exposure and stronger corporate separation, while retaining the evidence required for banks, advisers and the client's residence country.

A practical closing note

The honest answer to "do US bank accounts get reported?" depends

less on geography and more on the actual banking partner, the

account type and the way the LLC is structured. Once those three

variables are clarified with a knowledgeable advisor, the

question loses most of its emotional weight: the member knows

exactly what is reported, to whom, and on which schedule. From

that point onward, the file becomes a simple, well-documented

yearly routine rather than a recurring source of doubt.