FinCEN and the Fed just withdrew a plan to make banks collect customer data on cross-border transfers as small as $250. The proposal sat unfinished for six years and drew nearly 3,000 comments. Why it isn't over is below. • The proposal was issued in October 2020 and would have cut the threshold from $3,000 to $250 for transfers that begin or end outside the US • It covered convertible virtual currency too • Nearly 3,000 comments raised financial privacy, compliance cost and personal data collection concerns • Commenters said $250 would burden smaller institutions and could push remittance customers to less regulated channels • The $3,000 threshold stays, and suspicious activity reporting duties are unchanged • The notice is due in the Federal Register on Nov 9 Privacy pushback won this round. The agencies gave no replacement plan or timetable, and any future proposal goes back out for public comment. Withdrawn is not permanent. Transfers of $3,000 or more through a regulated middleman still come with a file on you. That's the price of letting someone else hold your money.
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