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The Fed and FinCEN Propose to Lower Reporting Threshold on International Transfers to $250

The Financial Crimes Enforcement Network (FinCEN), along with the Board of Governors of the Federal Reserve, recently proposed new rules related to the Bank Secrecy Act (BSA) and anti-money laundering regulations requiring financial institutions to collect and report information related to international transfers. The proposed changes would lower the threshold requiring when this information is collected from $3,000 to $250. The proposal also broadens the reporting rules to apply to digital or cryptocurrencies. The proposed rule changes are currently open for industry comments through November 27.

The Bank Secrecy Act requires financial institutions to collect and retain information on certain funds transfers and transmittals of funds, with the additional requirements being defined in the USA PATRIOT Act and Anti-Money Laundering Act.

Currently, all transfers $3,000 or more require certain information to be collected and transmitted to other financial institutions in the payment chain as well maintain records which can be considered for criminal, tax or regulatory investigations or proceedings. Under the proposed rule changes, the threshold for any funds transfers that being or end outside the United States would be lowered to $250 while there would be no change for domestic funds transfers.

Additionally, the Fed Board and FinCEN propose clarifying the reporting rules so they explicitly apply to virtual currencies or cryptocurrencies, applying the same thresholds of $250 for international transfers and $3,000 for domestic transfers. The proposal defines convertible virtual currencies (CVCs) as mediums of exchange that act as a substitute for currency or has an equivalent value as currency, explicitly including cryptocurrency under this definition of a CVC.

Industry experts and stakeholders are able to provide public comments through November 27, when the open comment period will close. Written comments may be provided via the Federal Reserve and/or FinCEN agency website, email, fax or mail delivered by courier.

For more information including how to submit comments:


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