The U.S. Treasury Department and the Federal Reserve Board have withdrawn a proposal that would have lowered certain international transfer reporting thresholds from $3,000 to $250, according to a joint withdrawal notice filed on Nov. 6. The withdrawal is scheduled to take effect upon publication on Nov. 9.
The proposal, originally published in October 2020, would have required covered banks and nonbank financial institutions to collect and retain information on smaller payments beginning or ending outside the United States. FinCEN’s Travel Rule would also have required specified information to accompany those payments between institutions. Domestic transfers would have retained the $3,000 threshold.
Crypto Provisions and Public Response
Separate cryptocurrency provisions in the proposal addressed both domestic and cross-border transactions. They would have explicitly covered convertible virtual currencies—digital value equivalent to or substituting for conventional currency—and digital assets with legal tender status to a recipient.
The agencies received nearly 3,000 comments from banks, money services businesses, trade associations, individuals, and others, with a significant majority consisting of substantially similar form letters. Respondents generally opposed the lower threshold, citing compliance costs for smaller institutions and risks from retaining more personal information. Some warned of disrupted overseas remittances or favored a higher threshold to reflect inflation since 1995.
Views differed on explicitly incorporating cryptocurrency transactions into the rules. Crypto service providers and related trade groups generally opposed that provision, while some banks, money services businesses, and associations supported it. Opponents cited technological limitations, the lack of an international messaging standard for crypto transactions, and potential constraints on innovation.
Commenters noted that some potentially illicit transfers below $3,000 were already reported through Suspicious Activity Reports. Broader objections included claims that the proposal would violate the U.S. Constitution’s Fourth Amendment protections against unreasonable searches and seizures.
Agencies Cite Market Changes and Stablecoin Law
The agencies identified the proposal’s age and developments in the crypto industry as their two primary reasons for withdrawal. More than five years had passed since the proposal was published, and they considered further public feedback useful before adopting similar amendments. They said no final rule on those amendments would be issued without another opportunity for public comment.
Maturing markets and emerging legal frameworks also informed the decision, including the GENIUS Act’s payment stablecoin framework. Enacted July 18, 2025, the law established federal rules for companies issuing payment stablecoins. Officials said potential crypto-related amendments should reflect these developments.
Last month brought separate withdrawals of wallet and mixer proposals involving self-hosted wallets and cryptocurrency mixing. Those proceedings addressed different proposed obligations from the international transfer threshold. The wallet proposal would have added recordkeeping for certain transactions above $3,000 and reporting for those above $10,000.
