FinCEN and the Federal Reserve have formally withdrawn a 2020 proposal that would have cut the Bank Secrecy Act threshold for cross-border funds transfers from $3,000 to $250 and spelled out that the rules cover crypto, leaving the existing $3,000 line in place.
The notice, published Monday in the Federal Register, says the Financial Crimes Enforcement Network and the Fed’s Board of Governors “will not take further action” on a proposal they first issued on Oct. 27, 2020.
That plan would have lowered the recordkeeping and Travel Rule thresholds to $250 for transfers that begin or end outside the United States. Those rules require banks and nonbank financial institutions to collect, retain and pass along customer information on transfers of $3,000 or more.
It also would have clarified the meaning of “money” in both rules so they apply to transactions involving convertible virtual currency, along with digital assets that have legal tender status to a recipient.
Why the agencies backed off
Per the notcie, FinCEN and the Fed received nearly 3,000 comments on the proposal, most of them substantially similar form letters. Commenters generally opposed the lower threshold, arguing that it would burden smaller institutions and could push consumers sending remittances toward less regulated channels.
Many also noted that potentially illicit transfers below $3,000 were already being flagged to FinCEN through suspicious activity reports. Several said the threshold should rise instead, citing inflation since 1995.
Sentiment on the crypto language was mixed. Companies that provide crypto services and their trade groups opposed it, citing technical limits and the lack of an international messaging standard for crypto transfers, while some banks and money services businesses supported it.
The agencies gave two reasons for pulling the proposal. More than five years have passed, and they said more public feedback would help before adopting anything similar. The withdrawal, they wrote, gives the public “certainty” that no final rule will be issued without another chance to comment.
The second reason is the crypto industry itself. The notice says crypto markets “have continued to mature” and new legal frameworks are emerging, citing the GENIUS Act stablecoin law enacted on July 18, 2025. Any future change tied to crypto, the agencies said, should be considered in light of those developments so it is “fit for purpose.”
What the withdrawal does and does not do
The notice does not repeal or amend any rule. The $3,000 threshold that has applied for decades stays where it is, and so does the existing Travel Rule.
What disappears is the specific path to $250 and the proposed wording that would have written crypto into the definition of money. The agencies did not say whether they plan a new proposal or offer a timeline.
The withdrawal is the latest in a run of reversals from Treasury. On Oct. 6, FinCEN scrapped its 2020 “unhosted wallet” proposal and a 2023 plan to label international crypto mixing a primary money laundering concern, a move Coin Center called a significant victory for financial privacy.
It does not signal a retreat from enforcement. On Friday, FinCEN cut off the MEXC exchange from the U.S. financial system over alleged sanctions evasion, using a different legal tool aimed at one named platform instead of a rule covering every institution.
Stablecoins are following their own track. Under the GENIUS Act, the Fed in June proposed customer identification requirements for stablecoin issuers, and FinCEN and the Treasury’s sanctions office proposed anti-money-laundering programs for the same firms in April.
For bitcoin users, the practical effect is that nothing changes: the $3,000 trigger stays, and the crypto-specific wording that industry groups opposed is gone for now.
Whether FinCEN and the Fed return with a new threshold, a crypto definition or neither will not be clear until one is published, and the agencies have committed to taking comments first.
