FinCEN and Fed Withdraw Proposal to Lower Transfer Threshold to $250

The Financial Crimes Enforcement Network (FinCEN) and Federal Reserve Board are withdrawing a 2020 proposal that would have lowered the U.S. threshold for recordkeeping and “travel rule” requirements on cross-border transfers to $250, keeping the current $3,000 threshold in place.

The agencies will take no further action on the plan, initially issued Oct. 27, 2020. It proposed lowering the cutoff from $3,000 to $250 for the two requirements, which set when covered transfers trigger recordkeeping and travel-rule obligations.

The proposal also would have specified that the rules applied to transactions involving convertible virtual currency (CVC) and digital assets with legal tender status. Its stated scope included domestic transactions in the United States and cross-border transfers.

The withdrawal means the proposed $250 cutoff will not take effect, and the existing $3,000 level remains in force. A notice formally withdrawing the proposal is scheduled to appear in the Federal Register on Nov. 9.