The Financial Crimes Enforcement Network and the Board of Governors of the Federal Reserve System are withdrawing a proposed rule from 2020 that would have lowered the dollar threshold for tracking international money transfers from $3,000 to $250. The withdrawal takes effect Nov. 9, 2026, according to a notice in the Federal Register. The agencies said they will take no further action on the proposal.
The proposal was never finalized, so the current threshold stays in place. Two rules, known as the Recordkeeping Rule and the Travel Rule, require banks and nonbank financial institutions to collect, keep and pass along information on transfers of $3,000 or more. The notice says the Recordkeeping Rule is issued jointly by the Board and FinCEN, which is part of the Treasury Department. FinCEN alone issues the Travel Rule.
The proposal was published Oct. 27, 2020. It would have applied the lower $250 threshold to transfers that begin or end outside the United States. It also would have made clear that both rules cover domestic and cross-border transactions involving convertible virtual currency, a term for digital money that can be exchanged for traditional currency, as well as any digital asset that counts as legal tender for the person receiving it.
The agencies said they received nearly 3,000 comments from banks, money services businesses, trade associations, individuals and others. A significant majority were substantially similar form letters, the notice says. Commenters generally opposed the lower threshold. Many argued that it would burden financial institutions, especially smaller ones, and could disrupt remittances sent overseas. Some said it could push consumers toward less regulated options.
Other commenters said the lower threshold would greatly increase the number of covered transactions and raise financial institutions’ liability for holding personal data. Some noted that suspicious transactions below $3,000 are already reported through Suspicious Activity Reports. Several said the agencies should raise the threshold instead, citing inflation since 1995. Some said the agencies had not provided enough analysis or data to support the change.
Comments on the virtual currency portion were mixed, the notice says. Companies offering virtual currency services and their trade associations generally opposed it. They cited technological limits, the lack of an international messaging standard and a risk to innovation. Some banks, money services businesses and related trade associations supported it.
The agencies gave two main reasons for withdrawing the proposal. First, more than five years have passed, and they said additional public feedback would be useful before they adopt any similar changes. The withdrawal is meant to give the public certainty that no final rule will be issued without another opportunity to comment.
Second, the agencies said the virtual currency industry has changed significantly since 2020. They said those markets have continued to mature and new legal frameworks are emerging. As an example, the notice cites a federal law enacted July 18, 2025, that created a regulatory framework for payment stablecoins, a type of digital currency. The agencies said any future changes on virtual currency should account for these developments.
The notice does not say whether the agencies plan a new proposal or when one might come. Jimmy L. Kirby, Deputy Director of FinCEN, signed for that agency. Benjamin McDonough, Secretary of the Board, signed for the Federal Reserve.