The FinCEN Travel Rule stays as it is. The US Financial Crimes Enforcement Network (FinCEN) and the Federal Reserve Board are formally withdrawing their 2020 proposal to cut the threshold for cross-border funds transfers from $3,000 to $250. The withdrawal is published on November 9, 2026, in the Federal Register (FR Doc. 2026-22809) and takes effect that day. Along with the lower threshold, the planned explicit clarification that the rules cover cryptocurrency is gone too. The agencies say they “will not take further action” on the proposal.
For banks, payment providers and crypto companies in the US, the immediate effect is simple: nothing changes. Existing obligations remain in force at the old $3,000 threshold. The move is still worth a closer look, because it fits into a series of withdrawals through which Washington is reshaping its approach to crypto oversight.
What the FinCEN Travel Rule covers
The label refers to two rules under the Bank Secrecy Act (BSA), the core US anti-money-laundering law. The Recordkeeping Rule requires banks and nonbank financial institutions to collect and retain certain information, such as details on the sender and recipient, for funds transfers of $3,000 or more. It is issued jointly by FinCEN and the Fed. The Travel Rule itself is issued by FinCEN alone: it requires that this information “travel” with the payment to the next institution in the chain. The $3,000 threshold dates back to 1995.
The 2020 proposal specifically targeted transfers that begin or end outside the United States. For those, the threshold would have dropped to $250, both for collecting and retaining the data and for passing it on.
What the 2020 proposal would have done
The joint notice of proposed rulemaking (NPRM) was published on October 27, 2020, at 85 FR 68005. According to the Federal Register, the comment period closed on November 27, 2020. The draft had two parts:
- Lower threshold: $250 instead of $3,000 for cross-border transfers, under both the Recordkeeping Rule and the Travel Rule.
- Crypto clarification: The definitions of “payment order” and “transmittal order” would have been revised to explicitly cover transactions involving convertible virtual currency (CVC) and digital assets with legal tender status, both domestic and cross-border.
Both parts are now off the table. No final rule will be issued on the basis of this proposal.
Why FinCEN and the Fed are pulling it
The notice gives two main reasons. First, more than five years have passed since the proposal was issued. Before adopting any similar amendments, the agencies want fresh public input. The withdrawal is meant to give the public certainty that no final rule will be issued without another opportunity to comment.
Second, the crypto industry has changed significantly since then: markets have matured and new legal frameworks are emerging. As an example, the document cites the GENIUS Act for payment stablecoins, enacted on July 18, 2025, as well as the White House digital assets report from July 2025. Any future amendments to the Recordkeeping Rule and Travel Rule related to crypto should be considered “in light of these recent developments” so that they are “fit for purpose.”
The notice is signed by Jimmy L. Kirby, Deputy Director of FinCEN, and, for the Fed, by Board Secretary Benjamin McDonough. According to the Federal Register, it was filed on November 6, 2026.
What commenters objected to
FinCEN says the proposal drew nearly 3,000 comments from depository institutions, money services businesses, trade associations, individuals and others. A significant majority were substantially similar form letters. The agency summarizes the main criticism as follows:
- A $250 threshold would impose a significant burden, especially on smaller institutions.
- It could disrupt remittances abroad and push consumers into less regulated channels.
- It would sharply increase the number of covered transactions, and with it the amount of stored personal data and the related liability exposure.
- Suspicious transactions below $3,000 were already being reported through Suspicious Activity Reports (SARs).
- The agencies had not provided enough data to justify the cut. Some commenters even called for a higher threshold to reflect inflation since 1995.
Reactions to the crypto part were mixed, according to FinCEN. Crypto service providers and their trade groups generally opposed it, citing technological limitations and the lack of an international messaging standard for crypto transfers at the time. Some banks and money services businesses supported it. Many commenters also raised broader privacy objections, including arguments under the Fourth Amendment.
What this means for crypto businesses
It matters what the withdrawal does not do. The Travel Rule still applies to US crypto service providers. In its interpretive guidance FIN-2019-G001 of May 9, 2019 (PDF), FinCEN had already explained that transactions involving convertible virtual currency can qualify as a “transmittal of funds.” A transfer of $3,000 or more, or its equivalent in crypto, may therefore trigger Travel Rule obligations. The guidance states explicitly that it creates no new requirements but interprets existing rules.
The 2020 proposal would have written that interpretation into the regulatory text itself. That step is now dropped. In practice, little changes in the short term: money services businesses handling crypto transfers still have to observe the $3,000 threshold. A cut to $250, however, is no longer on the table.
For users, this means that smaller international transfers and crypto transfers below $3,000 still do not trigger Travel Rule obligations in the US. That does not rule out checks by institutions, for example through suspicious activity reporting or internal compliance policies.
Part of a series of withdrawals
The step does not stand alone. On October 6, 2026, FinCEN had already withdrawn two other crypto proposals, both documented in the Federal Register. One was the December 23, 2020, proposal (85 FR 83840) that would have imposed reporting, recordkeeping and identity verification requirements on banks and money services businesses for transactions involving unhosted wallets. The other was the October 23, 2023, proposal (88 FR 72701) to designate international crypto mixing as a class of transactions of “primary money laundering concern” under Section 311 of the USA PATRIOT Act.
At the same time, FinCEN is showing that it is not retreating from crypto oversight but becoming more targeted. Only on November 6 did it issue an order against MEXC Global that bars US financial institutions from sending funds to the exchange. The pattern: fewer blanket obligations for small transactions, and tough measures against specific actors instead.
Our take
The withdrawal is mostly housekeeping. A proposal that had been dormant for more than five years is formally closed. That creates legal certainty, because companies no longer have to brace for a sudden finalization. The underlying question is not settled, though: FinCEN and the Fed explicitly leave room for future amendments, but only with a new rulemaking process and a new comment period.
For the industry, it is another relief after the October withdrawals. How the overall framework ends up will also depend on how the GENIUS Act is implemented, including the OCC’s final stablecoin rule for 2027, and on how the SEC proceeds with the plans we covered in our piece on the pushback against SEC Regulation Crypto Assets. The Travel Rule itself remains what it has been for years: an obligation starting at $3,000.
