The Financial Crimes Enforcement Network (FinCEN) and the Federal Reserve have formally withdrawn a 2020 proposal that would have required financial institutions to apply stricter reporting standards on cross-border transfers, including explicit coverage of cryptocurrency transactions.
Withdrawal of proposed changes
FinCEN announced on November 6 that it would not move forward with the notice of proposed rulemaking (NPRM) originally issued in 2020. The joint notice was subsequently published in the Federal Register on November 9. Both agencies confirmed they will not take further action on this proposal, leaving the current $3,000 threshold unchanged for international transfer reporting rules.
Under the existing framework, banks and other financial intermediaries must collect and retain sender and recipient details for transfers at or above $3,000, in accordance with the Recordkeeping Rule. The Travel Rule also requires institutions to transmit these details to the next financial entity involved in the transaction.
FinCEN and the Federal Reserve stated there will be no final rule without an additional opportunity for public comment, emphasizing the need for updated feedback before considering similar regulatory changes in the future.
Officials cited the age of the proposal and significant developments in the crypto sector as the main reasons for withdrawal. The NPRM, over five years old, no longer reflects the current landscape, and the agencies expressed a preference for renewed industry input.
Evolving regulatory landscape and public feedback
The agencies highlighted changes since 2020, describing how the market for convertible virtual currency (CVC)—digital assets that can serve as currency equivalents even without legal tender status—has evolved significantly, with new legal frameworks now in place.
The notice referenced the GENIUS Act: a federal law enacted in July 2025 focused on stablecoins, underscoring the need for any new crypto-related rules to consider such legislative advancements.
Mini dictionary: GENIUS Act – A piece of U.S. federal legislation passed in July 2025, establishing regulatory guidelines for the use and issuance of stablecoins.
FinCEN Deputy Director Jimmy L. Kirby and Benjamin McDonough, secretary of the Fed’s Board of Governors, signed the announcement. No additional comments from agency officials were included in the release.
Details of the original proposal and industry reactions
Initially, the 2020 proposal sought to lower the transaction reporting threshold from $3,000 to $250 for cross-border transfers and to clarify that the definition of “money” in the rules confidently extends to both CVCs and any digital assets recognized as legal tender. This would have broadened regulatory oversight for crypto transactions both inside and outside the United States. FinCEN’s 2019 guidance had already extended these requirements to some crypto transfers managed by nonbank service providers.
Public reaction to these proposed rules varied. Crypto service providers and industry associations largely opposed them, expressing concerns about operational burdens and data security. On the other hand, certain banks, money services businesses, and related trade associations offered support. The agencies received nearly 3,000 public comments, the majority of which objected to the lower threshold. Some respondents argued that inflation since 1995 justified a higher reporting limit, not a reduction, while others warned that a $250 minimum would place undue strain on smaller institutions, hinder remittance services for consumers, and increase liability for holding sensitive customer information.
Concerns included the possibility that reducing the reporting threshold to $250 would disrupt consumer remittances and expose firms to increased risks associated with data retention and compliance.
With the withdrawal of the NPRM, banks and crypto firms continue to follow existing protocols, as the current $3,000 threshold and reporting obligations under the Travel Rule remain unchanged. The proposal’s withdrawal signals that any future attempt to amend these requirements, particularly regarding crypto transactions, will require a new round of public comment and regulatory review.
