BSA Funds Transfer Recordkeeping and Travel Rule
Current understanding
FinCEN and the Federal Reserve withdrew their 2020 proposal to lower the Bank Secrecy Act Recordkeeping and Travel Rule thresholds from $3,000 to $250 for funds transfers and transmittals beginning or ending outside the United States. The proposal also would have clarified coverage of convertible virtual currencies and digital assets with legal tender status. The withdrawal leaves the existing rules unchanged; it does not repeal existing BSA obligations for covered digital-asset businesses.
Evidence log
- 2026-11-09 — Threshold for the Requirement To Collect, Retain, and Transmit Information on Funds Transfers and Transmittals of Funds That Begin or End Outside the United States, and Clarification of the Requirement To Collect, Retain, and Transmit Information on Transactions Involving Convertible Virtual Currencies and Digital Assets With Legal Tender Status; Withdrawal: cross-connection with crypto-digital-assets: The withdrawn proposal combined a lower international funds-transfer information threshold with clarification of the Recordkeeping and Travel Rules’ coverage of convertible virtual currencies and digital assets with legal tender status. (novelty: 3)
Open questions
Related
Contributing findings
Threshold for the Requirement To Collect, Retain, and Transmit Information on Funds Transfers and Transmittals of Funds That Begin or End Outside the United States, and Clarification of the Requirement To Collect, Retain, and Transmit Information on Transactions Involving Convertible Virtual Currencies and Digital Assets With Legal Tender Status; Withdrawal
09-nov-2026
novelty 3
per-area 3
introduces