Key Takeaways
The withdrawal is scheduled to take effect upon publication Nov. 9.Commenters challenged compliance costs and risks to personal information.Comparable amendments would require another public comment opportunity.
Treasury and Fed Drop Proposed $250 Transfer Threshold
The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and the Federal Reserve Board filed a joint withdrawal notice on Nov. 6, abandoning plans to lower certain international transfer thresholds from $3,000 to $250. The withdrawal is scheduled to take effect upon publication Nov. 9. Referring to the notice of proposed rulemaking (NPRM), a formal proposal inviting public comment, the agencies stated:
“The Agencies will not take further action on this NPRM.”
Under the proposed international transfer requirements, covered banks and nonbank financial institutions would have collected and retained information on smaller payments beginning or ending outside the United States. FinCEN’s Travel Rule would also have required specified information to accompany those payments between institutions. Domestic transfers would have retained the $3,000 threshold.
Separate cryptocurrency provisions in the proposal addressed both domestic and cross-border transactions. They would have explicitly covered convertible virtual currencies, meaning digital value equivalent to or substituting for conventional currency. The provisions also covered digital assets with legal tender status to a recipient.
Commenters Raised Compliance Costs and Privacy Objections
Nearly 3,000 comments reached the agencies from banks, money services businesses, trade associations, individuals, and others, with a significant majority consisting of substantially similar form letters. Respondents generally opposed the lower threshold, citing costs for smaller institutions and risks from retaining more personal information. Some warned of disrupted overseas remittances or favored a higher threshold to reflect inflation since 1995.
Views differed on explicitly incorporating cryptocurrency transactions into the rules. Crypto service providers and related trade groups generally opposed that provision, while some banks, money services businesses, and associations supported it. Opponents cited technological limitations, the lack of an international messaging standard for crypto transactions, and potential constraints on innovation.
Existing compliance obligations at centralized exchanges continue under applicable rules. Commenters noted that some potentially illicit transfers below $3,000 were already reported through Suspicious Activity Reports. Broader objections included claims that the proposal would violate the U.S. Constitution’s Fourth Amendment protections against unreasonable searches and seizures.
Agencies Cite Crypto Market Changes and Stablecoin Law
The agencies identified the proposal’s age and developments in the crypto industry as their two primary reasons for withdrawal. More than five years had passed since the agencies published the proposal in October 2020, and they considered further public feedback useful before adopting similar amendments. They said no final rule on those amendments would be issued without another opportunity for public comment.
Maturing markets and emerging legal frameworks also informed the decision, including the GENIUS Act’s payment stablecoin framework. Enacted July 18, 2025, the law established federal rules for companies issuing payment stablecoins. Officials said potential crypto-related amendments should reflect these developments.
Last month brought separate wallet and mixer proposal withdrawals involving self-hosted wallets and cryptocurrency mixing. Those proceedings addressed different proposed obligations from the international transfer threshold. The wallet proposal would have added recordkeeping for certain transactions above $3,000 and reporting for those above $10,000.
