FinCEN and the Federal Reserve Refused to Lower the Reporting Threshold for Transfers from $3,000 to $250

The Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of the Treasury and the Board of Governors of the Federal Reserve System (FRS) have withdrawn a joint proposal to amend rules on the collection, storage, and transmission of information on financial transfers. The initiative, presented back in October 2020, aimed to lower the threshold for certain international transactions from $3,000 to $250. The changes were also intended to clarify the application of requirements to transfers involving convertible virtual currencies and certain digital assets.

FinCEN announced the decision on November 6, 2026, and on November 9, the corresponding notice was published in the Federal Register and officially took effect. However, the regulators withdrew the proposal, which never became an active rule. Existing U.S. legal requirements for anti-money laundering and the transmission of information on financial transfers continue to apply.

What changes were proposed by FinCEN and the FRS

The joint proposal was published on October 27, 2020, and aimed to amend the Recordkeeping Rule and the Travel Rule. The first rule regulates the collection and storage of certain information on financial transfers, while the second requires the transmission of necessary information between financial institutions involved in the transaction. These mechanisms are applied under the U.S. Bank Secrecy Act (BSA).

One of the central proposals was to lower the established threshold from $3,000 to $250 for transfers that begin or end outside the U.S. Had the changes taken effect, additional smaller transactions would have been subject to the relevant requirements for the collection, storage, and transmission of information. This could have increased the volume of data processed by banks, payment companies, and other financial institutions.

Additionally, FinCEN and the FRS proposed clarifying definitions used in the rules to explicitly indicate their application to transfers involving convertible virtual currencies (CVC) and digital assets that have the status of legal tender for the recipient. This included both domestic and international transactions subject to the relevant regulatory provisions. However, the proposed clarifications did not become part of the active rules.

Why regulators abandoned the 2020 project

In the withdrawal document, FinCEN and the FRS cited two main reasons for revisiting the initial initiative. The first is related to the duration of the regulatory process: more than five years have passed since the publication of the proposal. During this time, the agencies received nearly 3,000 comments from financial institutions, professional associations, and individuals.

Many participants in the discussion opposed lowering the threshold for international transfers to $250. They pointed to additional costs, potential complications in cross-border money transfers, and an increase in the volume of personal information that financial institutions would have to store. Some remarks concerned the insufficient assessment of the consequences of the proposed changes and the need for a longer implementation period.

The second reason is related to changes in the digital asset market. Regulators noted the development of the cryptocurrency industry and the emergence of new legislative mechanisms, including the American GENIUS Act on payment stablecoins, adopted in July 2025. According to the agencies, any future amendments should take into account the updated conditions and undergo additional public discussion.

Existing Travel Rule requirements remain in effect

The withdrawal of the proposal does not mean the cancellation of the Recordkeeping Rule or the Travel Rule. For financial transfers subject to their provisions, existing requirements, including the $3,000 threshold, remain in effect. Financial institutions also continue to fulfill other applicable obligations related to customer identification, transaction monitoring, and the detection of suspicious activity.

The $3,000 threshold should not be considered a universal minimum below which transactions are not subject to scrutiny. Certain U.S. legal requirements may apply regardless of the transfer amount. Their application depends on the nature of the transaction, the status of the organization, and other conditions established by law.

For cryptocurrency exchanges, banks, and payment services, the decision primarily means there is no need to implement the proposed 2020 changes in their original form. Companies that considered this project in planning their compliance systems may revise related plans. However, existing AML and sanctions control procedures remain in force.

FinCEN simultaneously tightened restrictions on MEXC

On the same day, November 6, FinCEN announced a separate restrictive measure against the cryptocurrency exchange MEXC Global. The agency issued an order prohibiting U.S. financial institutions subject to its jurisdiction from conducting fund transfers involving MEXC. According to FinCEN, this measure is related to identified risks of money laundering and sanctions evasion.

Unlike the withdrawn Travel Rule proposal, the order regarding MEXC is directed at a specific organization. It provides for the restrictions to take effect 30 days after the publication of the relevant document in the Federal Register. Therefore, the decision cannot be described as an immediate cessation of all exchange operations or a global ban on its activities.

The two decisions illustrate the difference between general changes in regulatory requirements and targeted actions by a financial regulator. FinCEN and the FRS have abandoned the previous proposal to expand information collection, but this does not limit the application of existing powers to specific organizations. For participants in the cryptocurrency market, compliance with existing rules remains important regardless of the future of new regulatory initiatives.

What the decision means for cryptocurrency companies

For banks, cryptocurrency platforms, and international payment providers, the withdrawal of the proposal removes uncertainty surrounding the proposed reduction of the threshold to $250. Financial institutions no longer need to anticipate the adoption of this particular version of the amendments. However, the decision does not rule out the emergence of a new proposal with different conditions if regulators deem additional changes necessary.

This is particularly significant for companies operating in multiple jurisdictions simultaneously. American requirements for information transfer on transactions may differ from the rules of other countries, so withdrawing from a project in the US does not change obligations under foreign legislation. For international cryptocurrency services, regulatory differences remain one of the factors of operational costs and complexity of cross-border settlements.

Thus, FinCEN and the Federal Reserve decided not to proceed with the 2020 proposal to lower the threshold for international transfers from $3,000 to $250. Meanwhile, existing rules for storing and transferring information remain in place, and the possibility of future changes remains open. The further development of regulation will depend on new initiatives from the agencies and the results of their public discussions.