Joint survey underscores escalating technology expenses, manual workloads, and system limitations that hinder effective risk management

Washington, D.C. (December 2, 2025) – The American Fintech Council (AFC), the premier industry association representing responsible fintech companies and innovative banks, and the Coalition for Financial Ecosystem Standards (CFES), submitted a comment letter to the Financial Crimes Enforcement Network (FinCEN) in response to its Survey of the Costs of AML/CFT Compliance. The comments, informed by a joint AFC–CFES member survey conducted in November 2025, highlight the growing financial and operational pressures institutions face in meeting AML/CFT compliance requirements.

“Feedback from our members underscores the significant burdens institutions face in meeting AML/CFT obligations, particularly the escalating costs of personnel, technology, and vendor services required to maintain effective programs,” said Phil Goldfeder, CEO of the American Fintech Council. “We urge FinCEN to use these insights to shape risk-focused guidance that protects the financial system while reducing unnecessary operational strain.”

The joint survey collected data from AFC and CFES member institutions on AML/CFT expenditures, staffing needs, vendor costs, technology investments, and key compliance challenges. Respondents ranged from early-stage fintech companies to established financial institutions employing several thousand staff.  

Survey responses indicate that AML/CFT personnel and technology expenditures remain the largest components of compliance costs, with many institutions reporting millions in annual spending to maintain monitoring, alert review, onboarding, reporting, and transaction monitoring systems. Members also cited operational burdens including manual workflows, challenges integrating multiple vendor systems, inconsistent regulatory expectations, and limitations of legacy compliance systems in adapting to emerging fintech products and faster payment channels.

“Effective AML/CFT controls should be defined by outcomes, not by how much companies are spending. For too long the industry has been focused on process, to the exclusion of technology that can deliver on outcomes more efficiently ,” said Sima Gandhi, Co-Founder of the Coalition for Financial Ecosystem Standards. “Our members are sending a clear message: the status quo is becoming untenable, and there are clear opportunities to reduce burdens without compromising on the strength or effectiveness of AML/CFT measures.”

AFC also urged FinCEN to explore ways to incorporate innovative tools and processes into supervisory activities, as well as enable and incentivize the use of regulatory technology by innovative banks and their fintech partners. This would help reduce AML/CFT costs while strengthening BSA compliance.

“Fintech providers are committed to maintaining robust AML/CFT controls, but this data makes clear that costs and complexity continue to rise, often without proportional gains in risk reduction,” said Ian P. Moloney, Chief Policy Officer at AFC. “Data is crucial to pragmatic policymaking and regulation. By leveraging this industry feedback, FinCEN can promote supervisory frameworks that encourage responsible innovation, increase operational efficiency, and support more effective risk management across the financial sector”

A standards-based organization, AFC is the premier trade association representing the largest financial technology (Fintech) companies and innovative banks offering embedded finance solutions. AFC’s mission is to promote a transparent, inclusive, and customer-centric financial system by supporting responsible innovation in financial services and encouraging sound public policy. AFC members foster competition in consumer finance and pioneer products to better serve underserved consumer segments and geographies.

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