Summary of the Proposed Rule – Lowering the Recordkeeping and Travel Rules Thresholds and Revising Definition of “Money”

Updated 11/10/2020

This tool summarizes the FinCEN’s Proposed Rule of lowering information gather and reporting thresholds under the Recordkeeping Rule and Travel Rule, in addition to defining the term “money” to include digital assets for the purposes of the two rules. The following are the key takeaways of the changes:

  1. The information reporting and collecting threshold for the Recordkeeping Rule and Travel Rule from currently being $3,000, to $250.
  2. The new threshold will only apply to transfers originating or ending in the United States.
  3. Add a definition of the term “money” under the BSA, which will only apply to the Recordkeeping Rule and Travel Rule, and include convertible virtual currency (CVS) and other digital assets within its meaning.

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