Recently, FinCEN published a notice in the Federal Register requesting public comment on a proposed new information collection titled the “Survey of the Costs of Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Compliance.” The agency stated that it intended to gather data on the direct costs incurred by non-bank financial institutions, including insurance companies, credit card operators, loan and finance companies, money services businesses, casinos and card clubs, and dealers in precious metals, in meeting AML/CFT requirements.

The proposed survey would also request information on total direct compliance expenses, the share of operating costs attributable to AML/CFT, and how costs are allocated across activities such as suspicious activity reporting, customer identification, and compliance with the Office of Foreign Asset Control. The survey would also seek input on technology use, anti-financial crime activities beyond those necessary to comply with BSA requirements, and the utility of current monitoring and reporting. FinCEN stated the information collected would be used to assess the impact of AML/CFT regulations and may inform future “deregulatory proposals.” Comments will be due by December 1.