FinCEN and Federal Reserve Propose to Significantly Lower Threshold for International Funds Transfers Under Recordkeeping and Travel Rules

NYU Compliance & Enforcement Blog

Eytan J. Fisch Khalil N. Maalouf Wesley Lainé Greg Seidner

Skadden attorneys review proposed rules published in October 2020 by FinCEN and the Federal Reserve that would amend the Recordkeeping and Travel rules, reducing the applicable threshold for international funds transfers from $3,000 to $250 and formally extending the rules to cover convertible virtual currencies and digital assets used as legal tender.