FinCEN and the Federal Reserve announced on Monday that they will not pursue a 2020 proposal that sought to reduce the Bank Secrecy Act threshold for cross‑border funds transfers from $3,000 to $250. The notice, published in the Federal Register, also would have clarified that the rules apply to transactions involving convertible virtual currency and other digital assets.
Background of the proposal
The original plan, issued on Oct. 27, 2020, aimed to lower the record‑keeping and Travel Rule thresholds for transfers that begin or end outside the United States. Under current regulations, banks and non‑bank financial institutions must collect, retain, and share customer information for transfers of $3,000 or more. The proposal would have extended those requirements to transfers of $250 and explicitly defined “money” to include crypto‑related transactions.
Public feedback and reasons for withdrawal
FinCEN and the Fed received nearly 3,000 comments, many of which were similar form letters. Commenters generally opposed the lower threshold, arguing it would burden smaller institutions and could push remittance users toward less regulated channels. Some noted that transfers below $3,000 were already flagged through suspicious activity reports and suggested the threshold should be raised to account for inflation.
Opinions on the crypto language were mixed. Crypto service providers and trade groups opposed the change, citing technical limitations and the lack of an international messaging standard, while some banks and money‑services businesses supported it.
The agencies cited two main reasons for pulling the proposal: the passage of more than five years since its introduction, and the need for additional public input before adopting similar rules; and the continued maturation of crypto markets, highlighted by new legal frameworks such as the GENIUS Act stablecoin law enacted on July 18, 2025.
Implications of the withdrawal
The withdrawal does not amend or repeal any existing rule. The $3,000 threshold and the current Travel Rule remain in effect. What is removed is the specific pathway to a $250 threshold and the proposed wording that would have incorporated crypto into the definition of money.
This action follows other recent reversals by Treasury, including the scrapping of a 2020 “unhosted wallet” proposal and a 2023 plan to label international crypto mixing as a primary money‑laundering concern. It does not indicate a reduction in enforcement, as evidenced by FinCEN’s recent sanction‑related action against the MEXC exchange.
Future outlook
FinCEN and the Federal Reserve have not indicated whether a new proposal will be issued or provided a timeline for any future changes. The agencies have committed to seeking additional public comment before moving forward on any adjustments to thresholds or crypto definitions.
