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Form 114 US Person Definition | FBAR Tax Lawyer

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FinCEN Form 114 US Person definition is a highly important component of FBAR and US international tax compliance.  In this essay, I will discuss in detail the FinCEN Form 114 US Person definition and highlight some common issues that arise with respect to this definition.

Form 114 US Person Definition: What is Form 114 and What is its Relation to FBAR

FinCEN Form 114, Report of Foreign Bank and Financial Accounts (used to be TD F 90-22.1) is commonly known as FBAR, the Report of Foreign Bank and Financial Accounts. This form is used by US persons to report to the IRS a financial interest in or signatory authority over foreign financial accounts.  This is one of the most important forms that US taxpayers need to file in order to comply with their US international tax law requirements. A failure to file an FBAR when required may result in an imposition of severe IRS penalties.

Form 114 US Person Definition: Only US Persons are Required to File FBARs

It is important to understand that only “US Persons”, as defined by the IRS for the FBAR compliance purposes, are required to file FBARs.  What is the legal basis for this and where does this term “US Person” come from?

BSA (Bank Secrecy Act) §5314(a) states that the Secretary of the Treasury shall require a “resident or citizen of the United States or a person, in, and doing business in, the United States, to keep records, file reports”.  This seems like the FBAR requirement may apply a hugely broad group of people (far beyond US residents and citizens), especially if one takes into account that the “United States” is defined to include all 50 states, the District of Columbia, the territories, and insular possessions of the United States and the Indian lands as defined in the Indian Gaming Regulatory Act. 31 CFR §§1010.350(b) and 1010.100(hhh).  The territories and possessions of the United States include American Samoa, the Commonwealth of the Northern Mariana Islands, the Commonwealth of Puerto Rico, Guam, and the US Virgin Islands (see BSA Electronic Filing Requirements for Report of Foreign Bank and Financial Accounts (FinCEN Form 114), p. 5.).

Despite this initial impression, the actual definition that we use today is much smaller than what is mandated by §5314(a) and it is thanks to BSA §5314(b).  BSA §5314(b) states that the IRS has the discretion to interpret what this provision actually means and who is exempt from the FBAR filing requirement.

Armed with this authority, on February 26, 2010, the IRS issued proposed regulations, which for the first time defined that only “US Persons” needed to file FBARs. This is why we discuss the definition of a US Person when we discuss who is required to file FBARs.

Form 114 US Person Definition: Who is a Person

Before we turn to the definition of a “US Person”, we need to discuss who is considered to be a “Person” for the Form 114 purposes. Under 31 CFR §1010.350(b), a “person” includes:  natural persons (US citizens and US residents) and entities, including but not limited to: corporations, partnerships, trusts, or limited liability companies formed under the laws of the United States.  This definition includes entities disregarded for tax purposes (as long as they are US persons).

Additionally, pension and welfare plans are also US entities that need to file FBARs. See Amendment to the Bank Secrecy Act Regulations—Reports of Foreign Financial Accounts, 76 Fed. Reg. 10, 234 (Feb. 24, 2011); IRM 4.26.16.2.1.3(3) (06-24-21).  Even though the regulations do not mention it, the Form 114 instructions expand the “person” definition to estates.  It is important to note that, according to page 6 of the FBAR electronic filing instructions, an executor of an estate has a fiduciary obligation to file FBAR on behalf of the estate and on behalf of the decedent in the year following the decedent’s death.

Form 114 US Person Definition: General Definition of a US Person

The definition of a US person includes the following categories of persons:

(1) US citizens;

(2) residents of the United States;

(3) an entity, such as a corporation, partnership and a limited liability company, created or organized in the United States or under the laws of the United States;

(4) a trust formed under the laws of the United States; and

(5) an estate formed under the laws of the United States.

Let’s analyze each of these categories in more detail.

Form 114 US Person Definition: US Citizens

All US citizens are subject to the FBAR filing requirement, even minor children.  The general definition of a US citizen is contained in 8 USC §1401.

Form 114 US Person Definition: US Residents

All US residents are subject to FBAR filing requirements.  Pursuant to 31 CFR §1010.350(b)(2), the definition of “US residents” follows the definition of a resident alien under §7701(b) with one modification – the definition of the “United States” still follows 1010.100(hhh) described above. Also, see IRM 4.26.16.2.1.2 (11-06-15).

There are three classes of US residents: (1) US permanent residents; (2) persons who satisfied the Substantial Presence Test; and (3) persons who elected to be treated as US residents.  Let’s discuss each of these classes of US residents in more detail.

1.  US Permanent Residents (the “Green Card Test”)

A person is considered a US person if at any time during the calendar year the person has been lawfully granted the privilege of residing permanently in the United States under the immigration laws and such status has not been revoked. 26 USC §§7701(b)(1)(A)(i) and 7701(b)(6).

One of the most common issues occurs when a person has been issued a green card and he has not yet physically entered the United States. In such cases, this person would not be considered as a resident alien until he actually physically enters the United States. 26 USC §7701(b)(2)(A)(ii).  Once he enters the country, however, he becomes a US permanent resident and continues to be one until the green card is revoked or considered abandoned either judicially or administratively. See 26 CFR §301.7701(b)-1(b)(2) and 26 CFR §301.7701(b)-1(b)(3).

2.  Substantial Presence Test

Even if a person is not a US permanent resident, he may still be considered a US Person if he meets the IRC §7701(b)(3) substantial presence test.  In reality, there are two substantial presence tests.

The first substantial presence test is met if a person is physically present in the United States for at least 183 days during the calendar year. 26 USC §7701(b)(3).  The second substantial presence test is met if two conditions are satisfied: (1) the person is present in the United States for at least 31 days during the calendar year; and (2) the sum of the days on which this person was present in the United States during the current and the two preceding calendar years (multiplied by the fractions found in §7701(b)(3)(A)(ii)) equals to or exceeds 183 days. 26 USC 7701(b)(3)(A).

Let’s focus on the mechanics of the second calculation.  The way to determine whether the 183-day test is met is to add: (a) all days present in the United States during the current calendar year (i.e. the year for which you are trying to determine whether the Substantial Presence Test is met) + (b) one-third of the days spent in the United States in the year immediately preceding the current year + (c) one-sixth of the days spent in the United States in the second year preceding the current calendar year. See 26 USC §7701(b)(3).

Note that the Internal Revenue Code (IRC) provides a number of important exceptions to the Substantial Presence Test.  In this article, I am just providing the general rule.

3.  Election to be Treated as a US Resident Alien

A person who makes the first-year election to be treated as a US resident alien pursuant to §7701(b)(4) is a US Person for FBAR purposes.   Note, however, that this rule applies only to elections made under this provision.  A nonresident alien spouse of a US person who makes an election under the IRC §§6013(g) and 6013(h) to be treated as a resident alien will not be considered as a US person for the FBAR compliance purposes.  This is an important divergence between the income tax and FBAR rules.

Form 114 US Person Definition: US Entities, Trusts & Estates

Entities (corporations, partnerships, limited liability companies, et cetera), trusts and estates created, organized or formed in the United States or under the laws of the United States are generally considered to be US Persons for FBAR purposes.

A foreign subsidiary of a US parent will not have any FBAR obligations as long as it is not formed, created or organized under the laws of the United States. However, the US parent company may be required to include the foreign accounts of its foreign subsidiary on its FBAR. 31 CFR §1010.350(e)(2)(ii).

Moreover, a foreign entity organized in and under the laws of a foreign country will not be subject to the FBAR requirements even if it elects to be treated as a US entity for US tax purposes. See Amendment to the Bank Secrecy Act Regulations—Reports of Foreign Financial Accounts, 76 Fed. Reg. 10, 234-238 (Feb. 24, 2011).

Contact Sherayzen Law Office for Professional Help with Your FBAR Compliance

If you need questions concerning your FBAR compliance or a voluntary disclosure concerning your prior FBAR noncompliance, contact Sherayzen Law Office for professional help!  Our firm specializes in FBAR compliance and offshore voluntary disclosures to remedy prior FBAR noncompliance.

We have helped hundreds of clients around the world and we can help you! Contact Us Today to Schedule Your Confidential Consultation!

2020 FBAR Criminal Penalties | FBAR International Tax Lawyers

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2020 FBAR criminal penalties is a potential threat to any US taxpayer who willfully failed to file his FBARs or knowingly filed a false FBAR. In this essay, I would like to review the 2020 FBAR criminal penalties that these noncompliant US taxpayers may have to face.

2020 FBAR Criminal Penalties: Background Information

A lot of US taxpayers do not understand why the 2020 FBAR criminal penalties are so shockingly severe. These taxpayers question why failing to file a form that has nothing do with income tax calculation should potentially result in a jail sentence.

The answer to this questions lies in the legislative history of FBAR. First of all, it is important to understand that FBAR is not a tax form. The Report of Foreign Bank and Financial Accounts (“FBAR”) was born in 1970 out of the Bank Secrecy Act (“BSA”), in particular 31 U.S.C. §5314. This means that the initial primary purpose of the form was to fight financial crimes, money laundering and terrorism. In other words, FBAR was not initially created to combat tax evasion.

Rather, FBAR criminal penalties were structured from the very beginning for the purpose of punishing criminals engaged in financial crimes and/or terrorism. This is why the FBAR penalties are so severe and easily surpass the penalties of any tax form.

It was only 30 years later, after the enaction of The Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “USA Patriot Act”), that the enforcement of FBAR was turned over to the IRS allegedly to fight terrorism. Instead, the IRS almost immediately commenced using FBAR to fight the tax evasion schemes that utilized offshore accounts.

The Congress liked the IRS initiative and responded with the American Jobs Creation Act of 2004 (“2004 Jobs Act”). The 2004 Jobs Act further increased the FBAR existing penalties and created an new non-willful penalty of up to $10,000 per violation.

2020 FBAR Criminal Penalties: Description

Now that we understand why the 2020 FBAR criminal penalties are so severe, let’s describe what these penalties actually may be. There are three different 2020 FBAR criminal penalties associated with different FBAR violations.

First, a criminal penalty may be imposed under 26 U.S.C. 5322(a) and 31 C.F.R. § 103.59(b) for willful failure to file FBAR or retain records of a foreign account. The penalty is up to $250,000 or 5 years in prison or both.

Second, when the willful failure to file FBAR is combined with a violation of other US laws or the failure to file FBAR is “part of a pattern of any illegal activity involving more than $100,000 in a 12-month period”, then the IRS has the option of imposing a criminal penalty under 26 U.S.C. 5322(b) and 31 C.F.R. § 103.59(c). In this case, the penalty jumps to incredible $500,000 or 10 years in prison or both.

Finally, if a person willingly and knowingly files a false, fictitious or fraudulent FBAR, he may be penalized under 31 C.F.R. § 103.59(d). The penalty in this case may be $10,000 or 5 years or both.

Contact Sherayzen Law Office for Help With Past FBAR Violations

If you were required to file an FBAR but you have not done it, contact Sherayzen Law Office to explore your voluntary disclosure options. Our international tax law firm specializes in FBAR compliance and we have helped hundreds of US taxpayers around the world to resolve their past FBAR noncompliance while reducing and, in some cases, even eliminating their FBAR penalties.

We can help You! Contact Us Today to Schedule Your Confidential Consultation!

FBAR Voluntary Disclosure | International Tax Lawyer & Attorney

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I often receive calls from prospective clients who talk about FBAR voluntary disclosure. They usually have no clear idea of what is meant by this term and what its requirements are. In this article, I will discuss this concept of FBAR Voluntary Disclosure and explain how this concept covers a variety of offshore voluntary disclosure options.

FBAR Voluntary Disclosure: What is FBAR?

Before we discuss the meaning of FBAR Voluntary Disclosure, we need to understand what “FBAR” is. FBAR is an acronym for Report of Foreign Bank and Financial Accounts, officially known as FinCEN Form 114. US Persons must file FBAR to report their financial interest in or signatory authority or any other authority over foreign bank and financial accounts if the aggregate value of these accounts exceeds $10,000 at any point during a calendar year.

FBAR Voluntary Disclosure: Why FBAR Compliance Is So Important?

US taxpayers who fail to comply with their FBAR obligations may find themselves in an extremely difficult legal position, because FBAR has a highly complex and an exceptionally severe penalty system, which includes even criminal penalties for FBAR noncompliance. The form’s civil penalties include not only willful penalties, but also non-willful penalties – i.e. the IRS can assess FBAR penalties even if a taxpayer’s failure to file his FBARs was unintentional and accidental.

FBAR Voluntary Disclosure: What is Voluntary Disclosure?

“Voluntary disclosure” is a process by which taxpayers voluntarily self-correct their past noncompliance. When this process involves foreign assets, it is called “offshore voluntary disclosure”.

FBAR Voluntary Disclosure: Offshore Voluntary Disclosure Options (Tax Year 2020)

The IRS has created a number of voluntary disclosure programs to encourage taxpayers to come forward and correct their past US tax noncompliance. These offshore voluntary disclosure options include: Streamlined Domestic Offshore Procedures, Streamlined Foreign Offshore Procedures, Delinquent FBAR Submission Procedures, Delinquent International Information Return Submission Procedures (effectively discontinued several weeks ago), IRS Criminal Investigation Voluntary Disclosure Practice (used to be called “Traditional IRS Voluntary Disclosure”) and the now-closed OVDP (Offshore Voluntary Disclosure Process) and OVDI (Offshore Voluntary Disclosure Initiative).

Moreover, there is also a voluntary disclosure based on Reasonable Cause exception that is sometimes called “noisy disclosure”. This is not an official IRS voluntary disclosure program, but simply a voluntary disclosure venue based on specific provisions in the Internal Revenue Code.

Finally, some taxpayers attempt to do “quiet disclosures”. A quiet disclosure can mean a range of actions voluntarily taken by a taxpayer to comply with US international tax laws without officially informing the IRS about his past noncompliance with them. In other words, a taxpayer never takes advantage of any of the voluntary disclosure options and does not claim Reasonable Cause Exception defense; rather, he either files amended tax returns or simply starts to comply with US international tax laws without doing anything about his past noncompliance.

The IRS strongly disfavors quiet disclosures and does not consider them to be voluntary disclosures. In fact, the IRS has officially stated that the agency will try to identify the taxpayers who are doing it and audit them in order to impose penalties for past noncompliance.

FBAR Voluntary Disclosure Versus Offshore Voluntary Disclosure

You probably already noticed that I never listed “FBAR Voluntary Disclosure” as a voluntary disclosure option. The reason is because it is not an official voluntary disclosure option. Rather, FBAR Voluntary Disclosure is merely a term that refers to any offshore voluntary disclosure option involving past FBAR noncompliance (such as Streamlined Domestic Offshore Procedures).

Hence, when a prospective client calls me to discuss his FBAR voluntary disclosure, I know that he does not mean any specific offshore voluntary disclosure program but merely wishes to know what option he should use to voluntarily correct his past FBAR noncompliance.

Contact Sherayzen Law Office About Your FBAR Voluntary Disclosure

If you have not filed your required FBARs for prior years, you should contact Sherayzen Law Office as soon as possible. Sherayzen Law Office is a leader in offshore voluntary disclosures involving FBARs – this is our core specialty.

We have filed thousands of FBARs for hundreds of clients all over the world. We have prepared hundreds of voluntary disclosures under all offshore voluntary disclosure options, including Streamlined Domestic Offshore Procedures and Streamlined Foreign Offshore Procedures. We can help you!

Contact Us Today to Schedule Your Confidential Consultation!

2018 FBAR Currency Conversion Rates | FBAR Tax Lawyer & Attorney

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2018 FBAR and 2018 Form 8938 instructions both require that 2018 FBAR Currency Conversion Rates be used to report the required highest balances of foreign financial assets on these forms. In the case of 2018 Form 8938, the 2018 FBAR Currency Conversion Rates is the default choice, not an exclusive one.

The U.S. Department of Treasury  already published the 2018 FBAR Currency Conversion Rates online (they are called “Treasury’s Financial Management Service rates” or the “FMS rates”).

Since the 2018 FBAR Currency Conversion Rates are very important to US taxpayers, international tax lawyers and international tax accountants, Sherayzen Law Office provides the table below listing the official 2018 FBAR Currency Conversion Rates (note that the readers still need to refer to the official website for any updates).

 

Country – Currency

Foreign Currency to $1.00
AFGHANISTAN – AFGHANI

74.576
ALBANIA – LEK

107.05
ALGERIA – DINAR

117.898
ANGOLA – KWANZA

310.0000
ANTIGUA – BARBUDA – E. CARIBBEAN DOLLAR

2.7000
ARGENTINA – PESO

37.642
ARMENIA – DRAM

485.0000
AUSTRALIA – DOLLAR

1.4160
AUSTRIA – EURO

0.8720
AZERBAIJAN – NEW MANAT

1.7000
BAHAMAS – DOLLAR

1.0000
BAHRAIN – DINAR

0.3770
BANGLADESH – TAKA

84.0000
BARBADOS – DOLLAR

2.0200
BELARUS – NEW RUBLE

2.1600
BELGIUM – EURO

0.8720
BELIZE – DOLLAR

2.0000
BENIN – CFA FRANC

568.6500
BERMUDA – DOLLAR

1.0000
BOLIVIA – BOLIVIANO

6.8500
BOSNIA – MARKA

1.7060
BOTSWANA – PULA

10.6610
BRAZIL – REAL

3.8800
BRUNEI – DOLLAR

1.3610
BULGARIA – LEV

1.7070
BURKINA FASO – CFA FRANC

568.6500
BURUNDI – FRANC

1790.0000
CAMBODIA (KHMER) – RIEL

4103.0000
CAMEROON – CFA FRANC

603.8700
CANADA – DOLLAR

1.3620
CAPE VERDE – ESCUDO

94.8800
CAYMAN ISLANDS – DOLLAR

0.8200
CENTRAL AFRICAN REPUBLIC – CFA FRANC

603.8700
CHAD – CFA FRANC

603.8700
CHILE – PESO

693.0800
CHINA – RENMINBI

6.8760
COLOMBIA – PESO

3245.8000
COMOROS – FRANC

428.1400
CONGO, DEM. REP – CONGOLESE FRANC

1630.0000
COSTA RICA – COLON

603.5000
COTE D’IVOIRE – CFA FRANC

568.6500
CROATIA – KUNA

6.3100
CUBA – PESO

1.0000
CYPRUS – EURO

0.8720
CZECH REPUBLIC – KORUNA

21.9410
DENMARK – KRONE

6.5170
DJIBOUTI – FRANC

177.0000
DOMINICAN REPUBLIC – PESO

49.9400
ECUADOR – DOLARES

1.0000
EGYPT – POUND

17.8900
EL SALVADOR – DOLARES

1.0000
EQUATORIAL GUINEA – CFA FRANC

603.8700
ERITREA – NAKFA

15.0000
ESTONIA – EURO

0.8720
ETHIOPIA – BIRR

28.0400
EURO ZONE – EURO

0.8720
FIJI – DOLLAR

2.1080
FINLAND – EURO

0.8720
FRANCE – EURO

0.8720
GABON – CFA FRANC

603.8700
GAMBIA – DALASI

50.0000
GEORGIA – LARI

2.6700
GERMANY – EURO

0.8720
GHANA – CEDI

4.8250
GREECE – EURO

0.8720
GRENADA – EAST CARIBBEAN DOLLAR

2.7000
GUATEMALA – QUENTZAL

7.7150
GUINEA – FRANC

9076.0000
GUINEA BISSAU – CFA FRANC

568.6500
GUYANA – DOLLAR

215.0000
HAITI – GOURDE

77.1180
HONDURAS – LEMPIRA

25.0000
HONG KONG – DOLLAR

7.8320
HUNGARY – FORINT

280.1700
ICELAND – KRONA

116.1100
INDIA – RUPEE

69.8000
INDONESIA – RUPIAH

14440.0000
IRAN – RIAL

42000.0000
IRAQ – DINAR

1138.0000
IRELAND – EURO

0.8720
ISRAEL – SHEKEL

3.7490
ITALY – EURO

0.8720
JAMAICA – DOLLAR

126.0000
JAPAN – YEN

109.8500
JERUSALEM – SHEKEL

3.7490
JORDAN – DINAR

0.7080
KAZAKHSTAN – TENGE

375.1500
KENYA – SHILLING

101.8000
KOREA – WON

1114.4900
KOSOVO – EURO

0.8720
KUWAIT – DINAR

0.3030
KYRGYZSTAN – SOM

69.8000
LAOS – KIP

8535.0000
LATVIA – EURO

0.8720
LEBANON – POUND

1500.0000
LESOTHO – SOUTH AFRICAN RAND

14.3500
LIBERIA – DOLLAR

156.7100
LIBYA – DINAR

1.3860
LITHUANIA – EURO

0.8720
LUXEMBOURG – EURO

0.8720
MACAO – MOP

no listing
MACEDONIA FYROM – DENAR

53.5000
MADAGASCAR – ARIARY

3470.2000
MALAWI – KWACHA

733.0000
MALAYSIA – RINGGIT

4.1300
MALI – CFA FRANC

568.6500
MALTA – EURO

0.8720
MARSHALL ISLANDS – DOLLAR

1.0000
MARTINIQUE – EURO

0.8720
MAURITANIA – OUGUIYA

36.0000
MAURITIUS – RUPEE

34.1500
MEXICO – PESO

19.6540
MICRONESIA – DOLLAR

1.0000
MOLDOVA – LEU

16.9930
MONGOLIA – TUGRIK

2642.9200
MONTENEGRO – EURO

0.8720
MOROCCO – DIRHAM

9.5300
MOZAMBIQUE – METICAL

61.5300
MYANMAR – KYAT

1535.0000
NAMIBIA – DOLLAR

14.3500
NEPAL – RUPEE

111.6000
NETHERLANDS – EURO

0.8720
NETHERLANDS ANTILLES – GUILDER

1.7800
NEW ZEALAND – DOLLAR

1.4900
NICARAGUA – CORDOBA

32.3000
NIGER – CFA FRANC

568.6500
NIGERIA – NAIRA

361.0000
NORWAY – KRONE

8.6800
OMAN – RIAL

0.3850
PAKISTAN – RUPEE

138.6000
PALAU – DOLLAR

1.0000
PANAMA – BALBOA

1.0000
PAPUA NEW GUINEA – KINA

3.2840
PARAGUAY – GUARANI

5956.0000
PERU – NUEVO SOL

3.3750
PHILIPPINES – PESO

52.4900
POLAND – ZLOTY

3.7530
PORTUGAL – EURO

0.8720
QATAR – RIYAL

3.6400
ROMANIA – NEW LEU

4.0690
RUSSIA – RUBLE

69.6800
RWANDA – FRANC

890.0000
SAO TOME & PRINCIPE – NEW DOBRAS

21.5350
SAO TOME & PRINCIPE – DOBRAS

20941.0080
SAUDI ARABIA – RIYAL

3.7500
SENEGAL – CFA FRANC

568.6500
SERBIA – DINAR

103.3900
SEYCHELLES – RUPEE

13.5500
SIERRA LEONE – LEONE

8620.0000
SINGAPORE – DOLLAR

1.3610
SLOVAK REPUBLIC – EURO

0.8720
SLOVENIA – EURO

0.8720
SOLOMON ISLANDS – DOLLAR

7.7520
SOMALI – SHILLING

575.0000
SOUTH AFRICA – RAND

14.3500
SOUTH SUDANESE – POUND

153.7000
SPAIN – EURO

0.8720
SRI LANKA – RUPEE

182.6000
ST LUCIA – EC DOLLAR

2.7000
SUDAN – SUDANESE POUND

47.0000
SURINAME – GUILDER

7.5200
SWAZILAND – LILANGENI

14.3500
SWEDEN – KRONA

8.9380
SWITZERLAND – FRANC

0.9840
SYRIA – POUND

515.0000
TAIWAN – DOLLAR

30.5880
TAJIKISTAN – SOMONI

9.3500
TANZANIA – SHILLING

2295.0000
THAILAND – BAHT

32.3500
TIMOR – LESTE DILI

1.0000
TOGO – CFA FRANC

568.6500
TONGA – PA’ANGA

2.1730
TRINIDAD & TOBAGO – DOLLAR

6.7700
TUNISIA – DINAR

3.0090
TURKEY – LIRA

5.2830
TURKMENISTAN – NEW MANAT

3.4910
UGANDA – SHILLING

3705.0000
UKRAINE – HRYVNIA

27.7000
UNITED ARAB EMIRATES – DIRHAM

3.6730
UNITED KINGDOM – POUND STERLING

0.7810
URUGUAY – PESO

32.3200
UZBEKISTAN – SOM

8310.0000
VANUATU – VATU

111.6900
VENEZUELA – BOLIVAR – SOBERANO

563.9800
VENEZUELA – BOLIVAR – FUERTE

248832.0000
VIETNAM – DONG

23190.0000
WESTERN SAMOA – TALA

2.5350
YEMEN – RIAL

480.0000
ZAMBIA – NEW KWACHA

11.9000
ZIMBABWE – DOLLAR

1.0000