The US travel rule threshold stays at USD 3,000. On 6 November 2026 FinCEN and the Federal Reserve Board withdrew the proposal they published on 27 October 2020, which would have cut the threshold to USD 250 for funds transfers and transmittals of funds that begin or end outside the United States. The withdrawal was published in the Federal Register on 9 November 2026 as FR Doc. 2026-22809. For money transmitters, banks and crypto firms, the rules that apply today continue unchanged.
What was proposed in 2020
The 2020 proposal had three parts. It would have lowered the threshold in the recordkeeping rule, which requires financial institutions to collect and keep information on funds transfers, from USD 3,000 to USD 250 for cross-border transfers. It would have lowered the same threshold in FinCEN's travel rule, which requires that information to travel with the transfer to the next institution in the chain. And it would have defined "money" in both rules to cover convertible virtual currency (CVC) and digital assets with legal tender status, removing any doubt that crypto transfers are covered.
| Element of the 2020 proposal | Current rule | Proposed | Status |
|---|---|---|---|
| Recordkeeping threshold, cross-border transfers | USD 3,000 | USD 250 | Withdrawn |
| Travel rule threshold, cross-border transfers | USD 3,000 | USD 250 | Withdrawn |
| Recordkeeping and travel rule threshold, domestic transfers | USD 3,000 | No change | Unchanged |
| Express coverage of CVC and legal tender digital assets in the rule text | Covered through FinCEN guidance | Written into the definitions | Withdrawn |
Why the agencies withdrew it
The withdrawal notice gives two reasons. More than five years have passed, and the agencies want fresh public comment before making any similar change. And the crypto market and its legal framework have changed, including the GENIUS Act on payment stablecoins enacted on 18 July 2025, so any future rule on crypto should be designed with those changes in view. The agencies said they will not take further action on the 2020 proposal, which means no final rule will be issued without a new consultation.
The notice also records the comments received: nearly 3,000, mostly opposed to the lower threshold. Commenters argued it would add cost, especially for smaller institutions, disrupt remittances and could push customers to less regulated channels, and that suspicious transfers under USD 3,000 are already reported through suspicious activity reports.
What still applies
Nothing in the withdrawal reduces current obligations. The recordkeeping rule in 31 CFR 1020.410(a) for banks and 1010.410(e) for nonbank financial institutions, and the travel rule in 1010.410(f), continue to apply to transfers of USD 3,000 or more.
| Obligation | Applies to | What it requires |
|---|---|---|
| Recordkeeping (31 CFR 1010.410(e)) | Money transmitters and other nonbank financial institutions | For transmittals of USD 3,000 or more, collect and keep the transmittor's name, address, amount, date, payment instructions and recipient details; verify the identity of a transmittor who is not an established customer |
| Travel rule (31 CFR 1010.410(f)) | Banks and nonbank financial institutions | Pass the transmittor's and recipient's details to the next financial institution with any transmittal of USD 3,000 or more |
| Record retention (31 CFR 1010.430) | All covered institutions | Keep records for five years in a retrievable form |
| Crypto coverage (FIN-2019-G001) | Money transmitters dealing in CVC | Treat CVC transmittals as covered by the recordkeeping and travel rules |
| Suspicious activity reporting | MSBs at USD 2,000 or more | File SARs on suspicious transactions regardless of the travel rule threshold |
FinCEN's 2019 guidance on convertible virtual currencies remains in place. It states that the travel rule applies to transmittals of CVC by money transmitters, so a US crypto exchange sending USD 3,000 or more to another exchange must still pass the required information. The withdrawal only removes the plan to write that into the rule text and to lower the cross-border threshold.
Key dates
| Date | Event |
|---|---|
| 9 May 2019 | FinCEN guidance FIN-2019-G001 confirms the travel rule applies to crypto transmittals (still in force) |
| 27 October 2020 | FinCEN and the Federal Reserve publish the proposal to cut the cross-border threshold to USD 250 |
| 18 July 2025 | GENIUS Act on payment stablecoins enacted, cited by the agencies as a reason to rethink |
| 5 October 2026 | FinCEN withdraws the unhosted wallet and crypto mixing proposals |
| 6 November 2026 | FinCEN and the Federal Reserve announce the withdrawal of the 2020 proposal |
| 9 November 2026 | Withdrawal published in the Federal Register (FR Doc. 2026-22809) |
| 18 January 2027 | GENIUS Act takes effect, at the latest |
For firms, the practical effect dates from 9 November 2026: there is no longer a pending proposal to plan for, and any future change starts again with a new proposal.
How the rules apply to common business models
The recordkeeping rule sits with the institution that sends or receives a transmittal. The travel rule applies when there is another financial institution in the chain to pass the information to.
| Business model | Recordkeeping at USD 3,000 | Travel rule at USD 3,000 |
|---|---|---|
| Remittance company sending to a foreign payout partner | Yes, as transmittor's financial institution | Yes, information passes to the payout partner |
| Remittance company paying out a transfer from abroad | Yes, as recipient's financial institution | Receives the information from the sending institution |
| Crypto exchange sending to another exchange or custodian | Yes, under FIN-2019-G001 | Yes, the information goes to the receiving exchange |
| Crypto exchange sending to a customer's unhosted wallet | Yes, under FIN-2019-G001 | No receiving financial institution to pass information to |
| Bank wire on behalf of an MSB customer | Bank keeps its own records | Bank passes information in the payment message |
The same transmittal can involve several institutions, and each keeps its own records. A money transmitter that uses agents remains responsible for overseeing their compliance, including the records they keep and the information they pass on. Our guide to the FinCEN foreign agent alert covers agent oversight.
What to test now
The withdrawal is a good moment to test travel rule compliance against the current rule. These are the points worth checking.
- Incomplete data. Recipient addresses or account numbers missing for transfers at or above USD 3,000.
- Identity checks for non-customers. Transmittors who are not established customers sent without the identity verification the rule requires.
- Crypto counterparties. Information sent to the receiving exchange late, in an incompatible format or not at all.
- Retrieval. Records kept, but not retrievable by name or account within a reasonable time, as the rule requires.
- Agent data. Agent systems capturing less than the principal's own systems.
Each of these is a finding whether the threshold is USD 3,000 or USD 250, so the withdrawal does not reduce the work of getting them right.
Unhosted wallets and mixing: the earlier withdrawals
The travel rule withdrawal is the last of three. On 5 October 2026 FinCEN withdrew two other crypto proposals: the December 2020 proposal on recordkeeping, verification and reporting for transactions with unhosted wallets, and the October 2023 proposal to treat international CVC mixing as a class of transactions of primary money laundering concern. Together, the three withdrawals clear FinCEN's crypto rulemaking agenda from 2020 to 2023.
That does not mean less scrutiny. In the same month FinCEN proposed a special measure against the A7 network's sub-agents, and on 6 November 2026 it issued an order prohibiting transmittals involving MEXC Global. The focus has moved from broad new reporting rules to targeted action against specific networks. Our guide to the MEXC order covers what firms must do there.
What MSBs and crypto firms should check
The withdrawal is a chance to confirm that current controls are right, not to relax them.
- Threshold logic. Check that transaction monitoring and data capture trigger at USD 3,000 for both domestic and cross-border transfers, and that any work started for USD 250 is either stopped or kept as a deliberate, documented risk choice.
- Crypto transfers. Confirm that the firm collects and transmits travel rule data for CVC transfers of USD 3,000 or more, and that the travel rule solution is tested against counterparties' systems.
- Structuring. Make sure monitoring detects customers splitting transfers to stay under USD 3,000, and that alerts lead to SAR decisions.
- Policies. Update AML policies and the risk assessment that referred to the proposal, so examiners see current rules.
- State requirements. Check state money transmitter rules, which can set their own recordkeeping expectations, and international partners' rules where a lower threshold applies abroad.
Firms with UK or EU operations should remember that the UK and EU travel rules apply to crypto transfers with no minimum amount, so a single global standard may still need to be stricter than the US one. Our UK crypto travel rule guide explains the UK position.
What happens next
The agencies have said any future change will start with a new proposal and public comment, and that crypto-related changes will reflect developments such as the GENIUS Act. FinCEN's wider programme reform also continues: its proposed AML/CFT programme rule remains at the proposal stage. Our note on the FinCEN AML/CFT programme proposal tracks it, and our money transmitter compliance calendar lists the dates that do apply in 2027.