U.S. Treasury and Fed Withdraw 2020 Plan to Lower Cross-Border Transfer Threshold to $250

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U.S. Treasury’s FinCEN and the Federal Reserve have withdrawn a 2020 proposal to cut the cross-border transfer threshold from $3,000 to $250 under CFT rules. The joint notice filed on Nov. 6 will take effect Nov. 9 and halts further action on the rule change. The $3,000 threshold remains in place for covered transfers, including crypto cross-border transactions. The agencies cited the proposal's age and evolving crypto markets, noting the need for updated feedback. The decision affects liquidity and crypto markets indirectly by freezing regulatory requirements at current levels.

The U.S. Treasury's Financial Crimes Enforcement Network and the Federal Reserve Board have issued a joint notice withdrawing a 2020 proposal to lower the recordkeeping and information-sharing threshold for cross-border transfers from $3,000 to $250.

The notice was filed for public inspection on Friday, Nov. 6, and is scheduled for publication on Monday, Nov. 9, when the withdrawal takes effect. The agencies said they will take no further action on that proposal.

The plan would have required banks and nonbank financial institutions to collect, retain and pass along information for smaller transfers that begin or end outside the United States. It also would have revised regulatory definitions to explicitly cover domestic and cross-border transactions involving convertible virtual currency and digital assets with legal tender status.

The decision closes the outstanding travel-rule portion of a rollback The Defiant reported in October. FinCEN had already withdrawn its separate 2020 proposal targeting transactions with unhosted wallets and its 2023 proposal for enhanced reporting on international crypto mixing. The joint travel-rule proposal was still pending at the time.

The $3,000 Rule Remains

The withdrawal does not repeal the existing Recordkeeping and Travel Rules. Their $3,000 threshold remains in place for covered transfers, including cross-border transfers.

Under the current nonbank recordkeeping rule, a sending institution must obtain and retain information such as the sender's name and address, the amount, the execution date and the recipient's financial institution. The Travel Rule requires specified information to accompany the transfer to the next financial institution, including recipient details when received, subject to the rules' exceptions.

Crypto exchanges operating as covered money transmitters do not gain a blanket exemption. FinCEN's 2019 guidance says convertible virtual currency transactions qualify as transmittals of funds and may fall within the Travel Rule at $3,000 or more, or the equivalent in crypto. Required information must be obtained or provided before or at the time of the transfer; it can travel in a separate message rather than on the same system as the assets.

Why the Agencies Pulled Back

The agencies cited the age of the proposal and changes in the crypto industry. More than five years had passed, they said, making fresh public feedback useful before adopting similar amendments. The notice also points to maturing crypto markets and emerging legal frameworks, citing the GENIUS Act's payment-stablecoin framework and the July 2025 White House digital-assets report.

The agencies left open the possibility of future crypto-related amendments, saying those should reflect recent developments. For this proposal, however, the notice promises that “no final rule will be issued without an additional opportunity for public comment.”

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