United States Department of the Treasury: Treasury and Fed Withdraw $250 Travel Rule Threshold Proposal
Photo: Tim Kiser (w:User:Malepheasant) / Wikimedia Commons, CC BY-SA 2.5

Treasury and Fed Withdraw $250 Travel Rule Threshold Proposal

FinCEN and the Federal Reserve Board have withdrawn a 2020 proposal to lower the cross-border recordkeeping threshold from $3,000 to $250, effective Nov. 9. The existing Travel Rule still applies to crypto, and the agencies left room for future rules after public comment.

Hadi GhadbanNovember 6, 20263 min read
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FinCEN and the Federal Reserve Board have withdrawn a 2020 proposal that would have cut the recordkeeping and information-sharing threshold for cross-border transfers from $3,000 to $250. The existing $3,000 threshold stays in place, including for qualifying crypto transfers under FinCEN's guidance.

The joint notice was filed for public inspection on Friday, Nov. 6, and is scheduled for publication in the Federal Register on Monday, Nov. 9, when the withdrawal takes effect. The agencies said they will take no further action on the proposal.

What the proposal would have done

The 2020 proposal covered transfers that begin or end outside the US. It would also have revised regulatory definitions to explicitly reach convertible virtual currency and digital assets with legal tender status.

Under FinCEN's 2019 guidance, convertible virtual currency transactions can already fall under the Travel Rule at $3,000 or more. That remains the case. The withdrawal does not repeal the existing Recordkeeping and Travel Rules, and exchanges must still meet current anti-money-laundering and customer identification requirements.

Why the agencies pulled it

The notice cites the proposal's age, more than five years, along with changes in the crypto industry. It also points to the GENIUS Act's payment-stablecoin framework and the July 2025 White House digital-assets report.

The agencies did not close the door on future changes. The notice states:

"no final rule will be issued without an additional opportunity for public comment."

FinCEN and Federal Reserve Board, joint notice

That leaves room for later crypto-related amendments. Stricter requirements could return, but only after a new comment period.

Industry reaction

The proposal drew nearly 3,000 public comments, with objections centered on financial privacy, compliance costs and the personal data crypto businesses would have had to collect. The Blockchain Association raised similar objections in a November 2020 comment letter.

Gavin Zavatone, policy lead at the DeFi Education Fund, welcomed the withdrawal, arguing the proposed requirements would have placed unnecessary data collection burdens on crypto users and businesses. He said:

"Americans shouldn’t have to hand over their names, addresses, and account details just because they chose to move value on a blockchain,"

Gavin Zavatone

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Context

The decision closes out the travel-rule portion of a broader rollback. In October, FinCEN withdrew its separate 2020 proposal on unhosted wallets and its 2023 proposal for enhanced reporting on international crypto mixing; the joint travel-rule proposal was still pending at that point. None of these actions changes the underlying Travel Rule.

Abroad, the direction differs. South Korea removed its domestic threshold in August, requiring registered virtual asset service providers to share identifying information regardless of amount. Separately, the SEC's crypto broker rule is now under White House review.

Discussion

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