FinCEN and Federal Reserve Withdraw Proposal to Lower Wire Transfer Threshold to $250

Key Facts

The U.S. Treasury Department’s Financial Crimes Enforcement Network and the Board of Governors of the Federal Reserve System have withdrawn a proposal that would have lowered from $3,000 to $250 the threshold at which information-collection and retention requirements begin for certain cross-border funds transfers. A notice from the agencies said the joint proposal, published on October 27, 2020, will not be finalized. The withdrawal means existing rules remain the standard for covered transfers, including requirements to pass information between financial institutions in the payment chain. The action addresses a broader framework for transfers, not cryptocurrency transactions alone, although the proposal included clarifications concerning certain digital assets. The agencies said any similar changes would require another opportunity for public comment.

Existing rules required banks and nonbank financial institutions to collect, retain and transmit information on transfers of $3,000 or more. This includes recordkeeping requirements, as well as the information-transfer rule known as the “Travel Rule,” which requires transfer data to be passed to the next financial institution in the payment chain. The proposal would have lowered the threshold to $250 for transfers that begin or end outside the United States, both for collecting and retaining information and for transmitting it between institutions. The change would therefore have extended the rules to smaller transfers than those currently covered. FinCEN said in the proposal’s background that the threshold for retaining transfer information had not changed since 1995, and that its 2020 request for comment aimed to assess its effectiveness in combating money laundering.

The proposal did not only revise the dollar threshold. It also clarified that recordkeeping and information-transfer rules apply to domestic and cross-border transfers involving convertible virtual currency or a digital asset that the recipient treats as legal tender. The Federal Reserve said the agencies jointly proposed amending the recordkeeping rule under their shared authority, while FinCEN alone proposed amending the information-transfer rule under its authority. The board described existing obligations as requiring the collection, retention and transmission of certain information on transfers exceeding $3,000. The clarification on digital assets was part of an update to existing rules, alongside the lower threshold for international transfers. The proposal therefore combined an expansion of the types of funds covered by the rules with a change to the transfer amount that triggers information requirements.

The agencies received about 3,000 comments on the proposal from depository institutions, financial services companies, trade associations, individuals and others, according to the notice. The document added that a large majority of the comments came in substantially similar form letters. Opponents warned that adopting a $250 threshold could impose a significant regulatory burden on financial institutions. They also said lowering the threshold would increase the number of transfers subject to the rules and raise institutions’ exposure to liability for retaining personal information. These objections linked the broader scope of transfers requiring documentation to compliance costs and risks involved in handling customer data. The agencies cited these concerns in the record of comments they received on the proposal.

The agencies said that more than five years had passed since the proposal was issued and that additional public comment would be needed before making similar changes, citing both as reasons for its withdrawal. The notice also linked the decision to recent developments in the virtual currency industry and emerging legal frameworks since the proposal was published. One example is a federal law enacted on July 18, 2025, that established a regulatory framework for payment stablecoins. This legal development provides new context for the debate over applying transfer rules to digital assets following the proposal’s publication in 2020. The agencies said they were withdrawing the proposal to confirm that no final rule would be issued without another opportunity for public comment, and that they no longer intended to issue a final rule on it.

The notice was filed on November 6, 2026, and set November 9, 2026, as its publication date in the Federal Register. It said the withdrawal would take effect on the date of publication. That means the effective date is November 9, not the date the notice was filed. Existing requirements, including collecting, retaining and transmitting information for transfers of $3,000 or more, remain the basis after the proposal’s withdrawal. The agencies did not set a date in the notice for proposing a replacement change, saying only that another opportunity for public comment would be needed before any final rule.