June 2018 JD Supra

Virtual Currency (VC) storage comes in the form of a “wallet” with private digital keys. The “wallets” can be domiciled in VC exchanges that operate in the US or foreign jurisdictions.  VC exchanges domiciled in foreign jurisdictions that operate similarly to a financial institution and or brokerage operation can be viewed as Foreign Financial Institutions FFIs) and VC held at FFIs could be subject to FATCA and FBAR reporting requirements.

https://www.jdsupra.com/legalnews/if-my-virtual-currency-is-walking-33842/