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FinCEN and Fed Withdraw $250 Cross-Border Transfer Proposal

The joint plan covered recordkeeping; FinCEN separately proposed lowering its Travel Rule threshold. Both existing thresholds remain at $3,000.

Updated 2 min read
Pedestrians pass the Federal Reserve’s Marriner S. Eccles Building in Washington, D.C. / EconoTimes.ai (mono)
Pedestrians pass the Federal Reserve’s Marriner S. Eccles Building in Washington, D.C. / EconoTimes.ai (mono)

The Financial Crimes Enforcement Network (FinCEN) and Federal Reserve withdrew a joint plan to cut recordkeeping to $250 for some cross-border transfers; FinCEN separately ended its Travel Rule proposal, leaving both thresholds at $3,000.

The withdrawal took effect Nov. 9, according to a Federal Register notice identified as document 2026-22809 and 91 FR 70824. In 2020, the agencies proposed lowering the recordkeeping cutoff from $3,000 to $250 for transfers with an origin or destination outside the United States. Banks and nonbank financial institutions would have needed to keep records on a broader set of payments, including some below today's limit.

Separately, FinCEN proposed reducing its Travel Rule threshold from $3,000 to $250. That rule addresses information passed among financial institutions handling a transfer; the joint plan addressed records they must retain. The agencies also considered wording that would explicitly cover domestic and cross-border transactions involving convertible virtual currency or digital assets with legal tender status for a recipient. The withdrawal leaves the current $3,000 Travel Rule threshold intact and drops that proposed clarification.

The agencies received nearly 3,000 comments, with many submissions using similar form-letter text, the notice said. Some commenters said the lower threshold could increase regulatory burdens for smaller institutions, interfere with consumers' ability to send remittances and push them toward options with less oversight. Views on the proposed digital-asset wording diverged.

The $3,000 limit dates to 1995; some commenters argued inflation justified an increase, the notice said. FinCEN and the Fed cited the years since the proposal and shifts in cryptocurrency markets and applicable law in explaining their decision. The 2020 proposal will not be finalized, and any comparable change would need a new public-comment process.

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