The Financial Crimes Enforcement Network (FinCEN) and the Federal Reserve Board jointly announced on November 6 the withdrawal of a 2020 proposal that would have lowered funds-transfer thresholds from $3,000 to $250. The notice is scheduled for publication in the Federal Register on November 9, when the withdrawal takes effect. It is the latest dormant crypto proposal to be shelved, following earlier withdrawals of proposed rules targeting crypto wallets and mixers.

What the $250 Plan Would Have Changed, and Why It Stalled

Published on October 27, 2020, the joint proposal targeted two rules. Under the Recordkeeping Rule, issued by both agencies, banks and nonbank financial institutions must collect and retain details of funds transfers. Under the Travel Rule, issued by FinCEN alone, they must pass those details to the next institution in the payment chain. The proposal would have cut the threshold for both from $3,000 to $250 for transfers beginning or ending outside the United States.

It also sought to define “money” in both rules to include convertible virtual currency (FinCEN’s term for crypto such as bitcoin) and digital assets with legal-tender status, for domestic and cross-border transactions alike. Dropping that clarification exempts nothing: FinCEN’s 2019 crypto guidance already treats qualifying crypto transfers as subject to the Travel Rule.

The comment record ran heavily against the lower threshold. The agencies received nearly 3,000 comments, a large majority of them form letters, and most opposed the cut. Commenters warned of heavy costs for smaller institutions, disruption to overseas remittances that could push customers toward less regulated channels, and greater liability from holding more personal data. Some argued that suspicious payments under $3,000 already reach FinCEN through Suspicious Activity Reports. Others wanted the threshold, unchanged since 1995, raised for inflation.

The proposed crypto definition split opinion more evenly. Crypto firms and their trade groups opposed it, citing technical limits and the lack of an international messaging standard for crypto transfers, while some banks, money services businesses and their associations backed it.

In the withdrawal notice, the agencies give two reasons. More than five years have passed, and they want fresh public input before adopting anything similar. Crypto markets have also matured and new legal frameworks have emerged; the notice cites the GENIUS Act, the federal stablecoin law enacted on July 18, 2025.

For exchanges, nothing changes in practice. The $250 threshold never took effect, so the data they must collect today is unchanged. The more useful question is what that data covers and who sees it.

What U.S. Exchanges Must Collect and Share Today

For covered transfers of $3,000 or more, FinCEN’s nonbank rules impose two duties: keep a record, and pass specified details to the next institution. Depending on the institution’s role, those details can include the sender’s name and address, account number, the amount, the execution date and the receiving institution. If the sender supplies the recipient’s name or account, that information travels with the payment as well.

Neither duty involves the government. FinCEN’s Travel Rule questions and answers confirm that the rule does not require a report for each covered payment. Reporting to FinCEN runs through other channels, chiefly Suspicious Activity Reports, which money services businesses must file on suspicious transactions of $2,000 or more.

The data does not have to touch the blockchain either. The same 2019 guidance lets institutions send it through a separate message or system from the crypto itself, provided timing requirements are met. A block explorer may show only two addresses while the exchanges at each end have privately swapped names and account details. For nonbank institutions, these obligations are codified at 31 CFR 1010.410.

Why a $500 Transfer Can Still Draw Questions

The $3,000 trigger governs one set of data-sharing duties, not an exchange’s entire compliance program. U.S. platforms run risk-based anti-money-laundering monitoring with no fixed dollar floor, and sanctions screening applies to payments of any size. A small transfer that fits a suspicious pattern or touches a flagged address can draw scrutiny regardless of its value.

The receiving side matters too. Outside the United States, the bar sits considerably lower, and a U.S. exchange sending crypto to a foreign platform meets those rules at the other end of the transfer.

Where the Bar Sits Outside the U.S.

• International standard (FATF): USD/EUR 1,000. Countries may set a reduced-data threshold up to this level. Below it, the names of both parties and a wallet address or transaction reference should still accompany the transfer.
• European Union (Regulation 2023/1113): No minimum. The rules have applied to crypto transfers between service providers since December 30, 2024. Transfers above €1,000 involving a self-hosted wallet trigger checks that the customer owns or controls it.

Under the EU regulation, a receiving provider that gets a transfer without the required information can reject it, return it, suspend it or request the missing details before releasing the funds. A $500 transfer from a U.S. exchange to a Bulgarian platform can therefore stall over data that U.S. law alone would not demand, and the sending exchange may ask its customer for recipient details to avoid that.

Customers asked for extra information on a small transfer can ask which rule sits behind the request: U.S. law, the receiving platform’s jurisdiction or the exchange’s own risk policy. This withdrawal touches only the first, and only on paper.

What the Withdrawal Leaves Open

The agencies say any future crypto-related changes to the two rules should account for recent market and legal developments, but the notice sets out no replacement and states that no further action will be taken on the 2020 proposal.

That leaves both camps from the comment period without a live proposal. Supporters of tighter cross-border data rules lose the $250 plan, while commenters who wanted the 1995 threshold raised for inflation gain nothing: $3,000 stays as written, well above both benchmarks above.

The agencies say they withdrew the proposal so that “no final rule will be issued without an additional opportunity for public comment.” That makes a new proposed rule in the Federal Register the signal to watch. Any future change to the threshold or the crypto definitions would surface there, with a comment period, before it could bind exchanges.

The record: FR Doc. 2026-22809 · RIN 1506-AB41 · Withdraws 85 FR 68005 · Signed by Jimmy L. Kirby, Deputy Director of FinCEN, and Benjamin McDonough, Secretary of the Federal Reserve Board. The withdrawal notice is available for public inspection via the Federal Register.