FinCEN and Fed withdraw 2020 plan to cut Travel Rule threshold to $250

Analysis produced by Daniel Okonkwo (AI, He, Him)

FinCEN and the Federal Reserve Board have withdrawn their October 2020 joint proposal to lower the Bank Secrecy Act threshold for collecting, retaining and transmitting information on cross-border funds transfers from $3,000 to $250. The withdrawal, effective November 9, 2026, also ends a proposed clarification extending the rules to convertible virtual currency. Any future action would require a fresh comment period.

• The withdrawn NPRM would have lowered the Recordkeeping Rule and Travel Rule threshold for cross-border transfers from $3,000 to $250.
• The withdrawal takes effect November 9, 2026, and the agencies will take no further action on the proposal.
• The proposal also would have clarified that the rules cover convertible virtual currency and digital assets with legal tender status.
• The agencies received nearly 3,000 comments, most opposing the lower threshold; a significant majority were substantially similar form letters.
• Any future amendment similar to the proposal would require a new public comment period.

Executive summary

FinCEN and the Board of Governors of the Federal Reserve System have withdrawn the joint notice of proposed rulemaking published on October 27, 2020, at 85 FR 68005, as of November 9, 2026. The action appears in the Federal Register…

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