Yes, if the LLC has a financial interest in or signature authority over accounts outside the US worth more than $10,000 in total at any point in the year. A US LLC counts as a US person for FBAR even when it is disregarded for income tax. US accounts such as Mercury or Relay are not reported.
FBAR rules apply to US persons, and FinCEN treats an LLC formed in a US state as a US person. That stays true when the IRS disregards a single-member LLC for income tax. So the filing obligation sits with the LLC itself.
Add up the highest balance of every non-US account the LLC owns or can sign on during the calendar year. If the total goes over $10,000 at any moment, the LLC files. A Wise or Payoneer balance held outside the US, or a bank account in your home country opened in the LLC's name, can count. Accounts at US banks do not.
The FBAR is FinCEN Form 114, filed online through the BSA E-Filing System. It is due April 15, with an automatic extension to October 15. You do not request the extension.
The LLC's FBAR is separate from your personal tax affairs. A non-US owner does not file a personal FBAR because they own a US LLC. If you hold non-US accounts personally, that is a question for your home country's rules.
The FBAR is also separate from Form 5472, which most foreign-owned single-member LLCs file every year regardless of bank accounts.
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We prepare and file Form 5472 with the pro forma 1120 for foreign-owned LLCs.
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