In October 2025, the U.S. Financial Crimes Enforcement Network (FinCEN) launched a wide-ranging Request for Information (RFI) to examine the real and hidden costs of anti-money laundering and countering the financing of terrorism (AML/CFT) compliance. The core question is whether the resources financial institutions spend on AML yield sufficient value.
FinCEN is seeking detailed data from nonbank financial institutions, including casinos, money services businesses, insurers, dealers in precious metals or stones, credit card system operators, and finance or loan companies. The goal is to understand the spending specifically associated with AML/CFT obligations.
FinCEN wants to capture several key aspects. First, the direct and incremental costs—how much additional money is spent solely on AML/CFT compliance beyond normal operations. Second, overlap with other functions, such as fraud detection or IT infrastructure, and what portion of those costs should be attributed to AML/CFT. Third, the overall burden relative to resources, particularly for smaller players who may face disproportionate strain.
AML/CFT rules are often complex and stringent. Large banks can leverage economies of scale and established compliance infrastructures, while smaller nonbank institutions may struggle with limited resources. Collecting this cost data may allow FinCEN to reassess regulatory expectations and address where compliance burdens are unevenly distributed.
However, there are challenges. Segregating AML/CFT costs from broader operational or compliance costs can be difficult. The voluntary nature of the survey may lead to participation bias, with more capable institutions responding, potentially skewing results. Concerns about confidentiality and regulatory scrutiny may also affect participation. Finally, interpreting costs across different sectors requires care, as what is reasonable for a casino may differ vastly from a finance company or insurer.
The outcomes of this initiative could influence regulatory frameworks, possibly offering tailored relief to smaller institutions, supporting more informed policy debates on cost-effectiveness, and highlighting which compliance mandates actually produce measurable benefits.
FinCEN’s RFI represents a significant shift, emphasizing empirical cost-based evaluation over purely prescriptive rulemaking. The key question remains: does the benefit of AML oversight justify the financial and operational burden imposed on institutions?
