The Clearing House Association and the Bank Policy Institute (collectively, “the Associations”) jointly responded to the FDIC’s request for feedback on a proposed Survey of the Costs of AML/CFT Compliance. The Associations expressed support for the survey’s goal of reducing compliance burdens and suggested several refinements to improve its accuracy and utility. Among other things, the Associations recommended expanding the survey beyond one year (2024) to capture multi-year variability, coordinating with other federal agencies to do similar surveys for consistency, and ensuring confidentiality of responses to encourage candid participation.

The Associations also provided detailed feedback on each of the proposed survey questions. The letter explained that estimating total AML/CFT costs is complex because expenditures span multiple departments and shared resources. It also suggested clarifying whether OFAC and sanctions-related costs should be included in the cost estimates. As to questions about technology use and suspicious activity reporting (SARs), the Associations urge the survey to distinguish between manual and automated processes and to capture both direct and indirect compliance costs. Their comments emphasize that more granular data—aligned with AML/CFT “pillars” (i.e., due diligence, reporting, controls, and training)—would produce more actionable information. To read the full letter click here.