FinCEN, Fed Reserve pull 2020 proposal on cross-border transfer thresholds
Banks and nonbank financial institutions are no longer subject to a proposed $250 threshold change, effective November 9 2026.
On November 9, 2026, the Financial Crimes Enforcement Network and the Board of Governors of the Federal Reserve System withdrew the joint notice of proposed rulemaking (NPRM) published at 85 FR 68005 on October 27, 2020 (RIN 1506-AB41). The withdrawal means the agencies will not adopt the proposed amendments to 31 CFR parts 1010 and 1020.
The withdrawn proposal would have lowered the threshold at which the Recordkeeping Rule and the Travel Rule apply to funds transfers that begin or end outside the United States from $3,000 to $250. It also sought to clarify that "money" includes domestic and cross-border transactions involving convertible virtual currency or any digital asset that has legal-tender status to a recipient.
The agencies cited the receipt of nearly 3,000 comments, many of which argued that a $250 threshold would impose a disproportionate compliance burden - particularly on smaller institutions - and could disrupt remittance flows. Commenters also raised privacy concerns and questioned the lack of supporting data.
The agencies further noted that more than five years have elapsed since the NPRM's issuance and that recent developments - such as the GENIUS Act enacted July 18, 2025 and Executive Order 14178 issued January 31, 2025 - have reshaped the stablecoin and broader digital-asset landscape. Any future amendment will consider these changes.
Accordingly, the agencies will not take further action on the 2020 proposal, and no final rule will be issued without a new notice and comment period. (FR Doc 2026-22809).
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