On 10/23/2020, the Financial Crimes Enforcement Network (FinCEN) and the Federal Reserve Board jointly invited comment on a proposed rule that would amend the recordkeeping and travel rule regulations under the Bank Secrecy Act. Having joint authority, FinCEN and the Federal Reserve, are together proposing amendments to the recordkeeping rule, while FinCEN, pursuant to its sole authority, is proposing amendments to the travel rule.
FinCEN’s release outlines the proposals as follows:
“Under the current recordkeeping and travel rule regulations, financial institutions must collect, retain, and transmit certain information related to funds transfers and transmittals of funds over $3,000. The proposed rule lowers the applicable threshold from $3,000 to $250 for international transactions. The threshold for domestic transactions remains unchanged at $3,000.
The proposed rule also further clarifies that those regulations apply to transactions above the applicable threshold involving convertible virtual currencies, as well as transactions involving digital assets with legal tender status, by clarifying the meaning of “money” as used in certain defined terms.”
The Notice of Proposed Rulemaking can be found here.
