FinCEN and the Fed withdraw 2020 plan to cut the cross-border Travel Rule threshold to $250
FinCEN and the Federal Reserve Board have withdrawn a 2020 proposal that would have lowered the recordkeeping and Travel Rule threshold for cross-border funds transfers from $3,000 to $250 and clarified how the rules apply to convertible virtual currency.
On 6 November 2026 the Financial Crimes Enforcement Network (FinCEN) announced that it and the Board of Governors of the Federal Reserve System are withdrawing a proposed rule first published on 27 October 2020. The withdrawal notice appears in the Federal Register with a publication date of 9 November 2026.
The 2020 proposal would have lowered the threshold for the Recordkeeping Rule and the Travel Rule from $3,000 to $250 for funds transfers and transmittals of funds that begin or end outside the United States. The Recordkeeping Rule requires financial institutions to collect and keep information on funds transfers, and the Travel Rule requires them to pass certain information on to the next institution in the payment chain. The proposal would also have clarified that these rules apply to transactions involving convertible virtual currency (crypto) and digital assets with legal tender status.
In the notice, the agencies say that more than five years have passed since the proposal was issued and that there have been significant recent developments in the convertible virtual currency industry since then. They say the proposal is being withdrawn to give the public certainty that no final rule will be issued, and that they will take no further action on it.
Why it matters to AML professionals
Cross-border transfer and crypto teams should keep working to the thresholds in the rules currently in force, not to the $250 figure in the withdrawn proposal. Policies, procedures or training material that referred to the 2020 proposal as a likely future change may need to be updated.
Red flags in this case
- International transfers repeatedly sent just under a recordkeeping or reporting threshold
- Payment messages for cross-border transfers that arrive with missing or incomplete originator or beneficiary information
- A customer splitting one larger crypto transfer into many small transfers to different wallets
- Transfers routed through several intermediaries with no clear business reason
If this landed in your queue
- Check which threshold your institution's procedures apply to cross-border funds transfers and confirm it matches the rules in force
- Review whether incoming and outgoing transfers carry the originator and beneficiary information the Travel Rule requires
- Look for patterns of transfers structured just below internal or regulatory thresholds
- Update internal guidance that described the 2020 proposal as pending
Key terms
- Travel Rule
- A requirement that financial institutions pass certain originator and beneficiary information along with a funds transfer to the next institution.
- Recordkeeping Rule
- A requirement that financial institutions collect and keep records about funds transfers above a set amount.
- Convertible virtual currency (CVC)
- FinCEN's term for a virtual currency, such as bitcoin, that has an equivalent value in real currency or acts as a substitute for it.
Interview angle
What is the Travel Rule, and why does it matter for cross-border and crypto transfers?
Explain that the Travel Rule makes sure information about who sent and who receives a transfer moves with the payment, so each institution in the chain can screen and monitor it. Mention that thresholds decide which transfers are covered, and that proposals to change them can be withdrawn, so professionals should always work to the rules actually in force.
Sources
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