US FBAR BSA E-Filing without Windows

Note: your use of these unofficial instructions is at your own risk. They might or might not result in a correct filing.

Many US “persons”, including legal entities such as corporations, are obliged to report on their foreign (non-US) bank (and other financial) accounts via BSA E-Filing system. Starting with 2015, there's an online form that individuals can use to file FBAR. For other legal entities, a more complex system has to be used, and this system only supports Windows. In practice, though, filing is possible from other operating systems, albeit not without issues. ¹⁾ Here's a combination of software versions that sort of works (as of June 2016):

A moderately non-ancient Linux distro with 32-bit userland and a typical set of X desktop software and libraries installed
Adobe Acrobat Reader 9.5.5 for Linux, AdbeRdr9.5.5-1_i486linux_enu.bin (still latest for Linux as of this writing) ²⁾
Mozilla Firefox 17.0.1 (a later version will likely also work, but you might need to disable the builtin PDF viewer) for 32-bit x86

(For security, preferably use dedicated installs of these tools under a pseudo-user account or/and in a container or VM. Do not view untrusted PDFs and browse untrusted websites from this same account.)

Acrobat Reader must be configured as a plugin in Firefox. Simply having it launched on the PDF file or on the URL is not good enough, because the E-Filing system provides a PDF file with embedded JavaScript that (presumably) needs cookies from the logged in session. (With “acroread” invocation on a standalone PDF or on the URL, you won't be able to submit the filled out form - the JavaScript in it will keep saying you're not logged in.) To configure the plugin, symlink Acrobat Reader's nppdf.so (with full path to it) to the ~/.mozilla/plugins/ directory (or invoke /opt/Adobe/Reader9/Browser/install_browser_plugin, which might do this or something like it for you), then (re)start Firefox. Test that the plugin is working by visiting some trusted sample PDF file URL (outside of the E-Filing system for now, e.g. some IRS form on their website will do) - the PDF file contents should display inside the web browser window.

To actually fill out and file the form:

Log in to the E-Filing system ³⁾
Obtain your signing PIN via the “Manage PIN” link in the navigation on the left
Proceed with “File FinCEN Reports” → “Report 114 - FBAR” (also in the navigation on the left), which opens a new browser window (it may also maximize that new window, ouch - but you can revert it to a sane size manually)
Click “Open New Form” (or “Open Existing Form” if you've previously saved a partially filled out PDF form locally)
Acrobat Reader 9.5.5 should complain about “a new format that this version of Acrobat does not support” once or twice (click “OK”), and the form should appear in the same browser window (sometimes the window just stays blank - if so, you may need to “Reload Tab” once or twice).
Save the blank form to a PDF file by clicking the form's own “Save” button. Close the window. ⁴⁾
Load the blank form PDF file into the same version of Acrobat Reader invoked standalone (not via Firefox) ⁵⁾
Fill out the form (BTW, the “Filing Name” is an arbitrary name you give to this filing for your own use/tracking), click “Validate” (it should complain about the lack of signature only), click “Sign with PIN” (and enter the PIN to the JavaScript pop-up that will appear)
You should not click “Submit” yet, and you should not click “Save”. ⁶⁾ Instead, close the window (yes, this is counter-intuitive). Acrobat (or a JavaScript?) will ask you if you want to save - click “Yes”. Then it will say it cannot save to the same filename, and offer to save to another - agree to that (and you may change the filename to any one you like).
Proceed with “File FinCEN Reports” → “Report 114 - FBAR” again, and “Open Existing Form” with your filename from the previous step. This time, if you did sign the form in the previous step, you'll be able to click Submit - do it.
You'll receive a pop-up giving you a “Tracking ID” (assigned by the system) and other info
Also click “Track Status” in the navigation on the left to see your submission there in the “Accepted” state. The state should change to “Transmitted” after a while (check it on the next business day)
Click “Logoff”

¹⁾ It is possible to side-step this entire process with Idividuals Filing FBAR and choosing the PDF Form option. It should work with any Acrobat Reader v10 or greater. Caveat: you should register an account with FinCen.gov before submitting, so that you can check your filing status.

²⁾ In 2014, BSA E-Filing system requirements listed Acrobat Reader 9.5 as the oldest supported version, so 9.5.5 was formally “supported”; unfortunately, this is no longer the case in 2015 and 2016, yet we're going to use this “unsupported” version for these instructions.

³⁾ If you cannot log in with your last year's credentials, e-mail the helpdesk - they have disabled some accounts “for inactivity” between mid-2015 and mid-2016, yet are willing to re-enable them based on a simple e-mail message.

⁴⁾ This and the next few steps are needed because the “Submit” button would just stay grayed out if you filled out and signed the form right in the browser window. There appears to be some issue with handling of the form's JavaScript's savedAfterSigned variable on this setup, and loading an already signed form bypasses that. This analysis is unconfirmed, though.

⁵⁾ Use of standalone Acrobat Reader also gives you the option to take advantage of the “Document” → “Forms” → “Export Data” / “Import Data” menu items, which let you save and reuse next year the unchanged form fields, via an XML file.

⁶⁾ If you do, Acrobat somehow saves the original PDF without your form inputs, and then it might not ask you to save changes when you exit it.