The US Financial Crimes Enforcement Network and Federal Reserve have filed a notice to withdraw a 2020 proposal that would have lowered the threshold for information duties on covered cross-border transfers from $3,000 to $250. The same proposal sought to clarify how the Recordkeeping and Travel Rules apply to convertible virtual currency and certain other digital assets.
The joint withdrawal notice was filed on November 6, 2026, and is scheduled for Federal Register publication on November 9. It specifies withdrawal on publication. As of November 7, the document remains on public inspection, so the withdrawal has not yet taken effect.
The agencies say they will take no further action on that proposal. Existing Recordkeeping and Travel Rule obligations remain in place. The notice concerns a proposed amendment rather than repealing those rules or creating a general exemption from anti-money-laundering requirements.
What the $250 proposal covered
The joint proposal was published on October 27, 2020. It would have reduced the threshold for collecting and retaining certain information about funds transfers that begin or end outside the United States. FinCEN separately proposed the same reduction for information passed between financial institutions along the payment chain.
These are related but distinct obligations under the Bank Secrecy Act framework. The Recordkeeping Rule, issued jointly by FinCEN and the Federal Reserve, deals with collecting and keeping information. The Travel Rule, issued by FinCEN, requires information to accompany a transfer between institutions. The withdrawal notice describes the existing rules as covering qualifying transfers of $3,000 or more.
The proposed $250 threshold was therefore about when these information duties would apply to covered international transfers. It was not a proposed $250 limit on how much a person could transfer. Passing information to another institution in a payment chain is also different from filing a report with the government.
The digital-asset provision had a different reach. By revising the definitions of payment order and transmittal order, the agencies had proposed clarifying that the rules cover domestic as well as cross-border transactions involving convertible virtual currency. The proposed wording also covered digital assets with legal-tender status to a recipient.
Fresh public feedback before similar changes
The agencies give two main reasons for withdrawing the proposal. More than five years have passed since it was issued, and they consider further public feedback useful before adopting similar amendments. They say withdrawal provides certainty that no final rule will follow without another opportunity for public comment.
They also point to changes in the convertible virtual currency industry and its legal framework. The notice cites maturing markets and emerging regulation, including the US payment-stablecoin framework enacted through the GENIUS Act on July 18, 2025. It says any future amendments concerning virtual currency should account for those developments.
The withdrawal does not rule out another proposal on the subject. The notice discusses potential future amendments but gives no timetable for a replacement consultation. When it takes effect, it will close the 2020 proposal rather than carry it into a final rule using the old consultation record.
Comments opposed the threshold reduction
The agencies received nearly 3,000 comments from financial institutions, trade associations, individuals and others. A substantial majority were similar form letters. The notice says commenters generally opposed lowering the thresholds for international transactions, while views on the proposed virtual-currency clarification were mixed.
Many commenters argued that the $250 threshold would increase compliance costs, particularly for smaller institutions. They also raised possible disruption to overseas remittances and increased exposure from holding personal information. Some questioned whether the agencies had supplied enough evidence to justify the reduction. These are arguments summarised in the notice, rather than findings that the agencies independently established.
Companies providing virtual-currency services and their trade associations generally opposed the clarification concerning those transactions. Some banks, money services businesses and related associations supported it. Opponents cited technical difficulties, including the absence of an international messaging standard at the time, and argued for better coordination among regulators.
The comments also illustrate why the $3,000 threshold cannot be read as a blanket reporting exemption. Some respondents said potentially illicit transactions below that amount were already being reported to FinCEN through Suspicious Activity Reports. Those reports serve a separate purpose from retaining transfer information and transmitting it along a payment chain.
For separate jurisdictional background, Dalimss News has covered the FCA's proposed crypto financial-crime guidance and India's virtual-asset customer-verification requirements.
