WASHINGTON–The financial cost to depository institutions—including credit unions– of complying with Bank Secrecy Act (BSA) anti-money laundering and countering the financing of terrorism (AML/CFT) requirements will be sought in an agency information collection proposed for Office of Management and Budget (OMB) approval.
According to a notice in the Federal Register, as part of the request for approval, the FDIC will be seeking comments from the public on the utility of the information being sought, the accuracy of burden estimate, etc. The FDIC plans to submit the information collection as a “common form” so other federal banking agencies and NCUA can then use it “to survey the entirety of the banking and credit union industry.”

The proposed survey questionnaire now available on the FDIC website will be used “to shape deregulatory proposals consistent with the executive prders of the Trump administration.”
What’s Being Sought
The notice said the proposed survey seeks:
- The institution’s costs in 2024 related to compliance with the Bank Secrecy Act (BSA) and implementing regulations
- Which areas (listed in the survey) of compliance program activity utilize technological resources
- What percentages of AML/CTF costs are related to the production of suspicious activity reports (SARs) and, separately (and optional), 13 other listed activities
- Percentage of AML/CTF costs related to OFAC compliance
- Whether the FI conducts anti-financial crime activities or maintains systems designed to combat financial crime not directly required by the BSA or its implementing regs, and their direct costs in 2024
- The percentage of operating expenses related to these direct costs in 2024.
After publication in the Register it will be out for comment for 60 days.







