FinCEN and Fed drop $250 cross-border transfer plan

FinCEN and the Federal Reserve have withdrawn a 2020 proposal that would have cut the Bank Secrecy Act threshold for cross-border transfers from $3,000 to $250 and written crypto into the rules.

The notice, published Monday in the Federal Register and reported by Bitcoin Magazine, says the agencies “will not take further action” on the proposal they issued on Oct. 27, 2020. It would have cut recordkeeping and Travel Rule thresholds to $250 for transfers that begin or end outside the United States and clarified “money” to include convertible virtual currency and digital assets with legal tender status.

For advisors, nothing changes today: no rule is repealed or amended, and clients who send wires abroad or hold convertible virtual currency keep the same obligations they have now. The $3,000 line for collecting, retaining and passing along customer information stands, and suspicious activity reporting already flags transfers below it. Compliance manuals, vendor thresholds and escalation triggers built around that figure remain accurate.

Commenters filed nearly 3,000 responses and generally opposed the lower threshold, arguing it would burden smaller institutions and push remittance senders toward less regulated channels. Many noted that potentially illicit transfers below $3,000 were already flagged through suspicious activity reports; some argued the threshold should rise because of inflation since 1995. Crypto companies opposed the crypto language, citing technical limits and no international messaging standard, while some banks and money services businesses supported it.

The agencies gave two reasons for withdrawing it. More than five years have passed, and they said more public feedback would help before adopting anything similar. The withdrawal gives the public “certainty” that no final rule will be issued without another comment period. They also said crypto markets have continued to mature and new legal frameworks are emerging, citing the GENIUS Act stablecoin law enacted July 18, 2025. Any future crypto change should be weighed against those developments so it is “fit for purpose.”