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FinCEN and the Federal Reserve withdraw the 2020 travel rule amendment proposal, cross-border transfer recordkeeping threshold remains at $3,000.

BlockBeats news, November 9 — The U.S. Financial Crimes Enforcement Network (FinCEN) and the Federal Reserve have withdrawn a notice of proposed rulemaking issued in 2020. The proposal had originally planned to lower the recordkeeping and travel rule thresholds for cross-border transfers from $3,000 to $250, and to explicitly include convertible virtual currency and digital assets serving as legal tender in the definition of "currency" under the rules. FinCEN announced the withdrawal on November 6, and the joint notice was published in the Federal Register on November 9. The two agencies stated they "will not take further action on the proposed rule," and the current $3,000 threshold remains unchanged. The recordkeeping rule requires institutions to collect and retain information on the sender and recipient, while the travel rule requires that this information be transmitted with the transfer to the next handling institution.

The agencies gave two reasons: the proposal is more than five years old, and they wish to obtain new public feedback before proceeding again to ensure that "no final rule will be issued without a new round of public comment"; they also noted that the convertible virtual currency market continues to mature and new legal frameworks are taking shape, citing the federal stablecoin law enacted in July 2025, the GENIUS Act, and stating that future revisions to the above rules should incorporate these changes. The notice was signed by FinCEN Deputy Director Jimmy L. Kirby and Federal Reserve Board Secretary Benjamin McDonough.

The proposal also sought to clarify that, for both domestic and cross-border transfers, "currency" includes convertible virtual currency and digital assets serving as legal tender. FinCEN's May 2019 guidance had already indicated that crypto transfers processed by non-bank institutions may be subject to the two rules above. The proposal received nearly 3,000 comments, most of which were form letters, with commenters broadly opposing the lowering of the threshold. Crypto service providers and their industry associations broadly opposed the language bringing cryptocurrency into the rules, while some banks, money services businesses, and their associations expressed support. Opponents argued that inflation since 1995 supports raising rather than lowering the threshold, and expressed concern that a $250 threshold would increase the burden on financial institutions, especially smaller ones, affect cross-border remittances, and increase liability risks associated with retaining personal information. The withdrawal does not relax existing travel rule obligations; it merely ends a pending proposal that had been stalled for about six years. Any future effort to lower the cross-border threshold or bring cryptocurrency into the definition would require a new public comment process.

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