The Financial Crimes Enforcement Network (FinCEN) and the Federal Reserve (Fed) issued a joint proposal on Oct. 23, 2020, to reduce the transaction volume threshold for when financial institutions must collect and retain information on funds transfers and remittances that start or end outside the U.S. The proposal would reduce the threshold from $3,000 to $250 for when financial institutions must comply with the recordkeeping and travel rules under the Bank Secrecy Act (BSA).
This proposal would amend both the recordkeeping and travel rules. In addition, the proposal also clarifies the definition of “money,” which included convertible virtual currencies (e.g., Bitcoin) that have an equivalent value as currency or act as a substitute for currency but do not have legal status. Comments to this proposal are due by Nov. 26, 2020.
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