Project 2025 Tracker / What’s done, what’s next

22. Department of the Treasury · Minor · Needs Congress

Require FinCEN to publish annual anti-money-laundering data

Attempted

Printed page 707 22. Department of the Treasury

“Congress must require FinCEN to annually publish data regarding: … The number of SARs filed; … The number of CTRs filed; … Annual estimates of the aggregate costs imposed on private entities by the AML-CFT regime.”

What has happened

  1. Attempted

    The survey cleared the Office of Information and Regulatory Affairs. FinCEN's 30-day submission notice of 2026-04-28 sets out what it is — a **new** collection, OMB control number then "1506-NEW", 7,457 estimated responses at 8 hours each for 59,656 burden hours, whose results "will help assess the cumulative impact of AML/CFT regulations and may inform efforts to adjust regulatory obligations and advance deregulatory proposals consistent with the Executive Orders of the Trump Administration" — and discloses that it is a pilot: "FinCEN will pilot the survey by distributing it exclusively to MSBs through MSB trade associations, rather than attempting to reach all NBFIs in the first instance." OIRA approved it without change on 2026-06-25 as control number 1506-0087, expiring 2029-06-30. Still `attempted`, and for three reasons: nothing has been collected or published, the pilot reaches money services businesses rather than the private sector at large, and no annual publication duty exists — a Paperwork Reduction Act clearance authorizes a collection, it does not require a report. **The other two datasets the Quote names went the wrong way in the same period.** FinCEN's published filing-trends series covers suspicious activity reports only and stops at calendar year 2024: `fincen.gov/resources/reports/sar-stats/sar-filings-industry` is headed "SAR Filings by Industry — For the period January 1, 2014 to December 31, 2024", its eight spreadsheets were last modified on 2025-08-22, and no calendar-2025 update had appeared thirteen months later. And there is **no currency-transaction-report filing statistics publication at all**: all 2,876 URLs in FinCEN's sitemap were grepped for `sar-stats|filing-trend|statistic|ctr`, and every CTR hit is a FAQ, an administrative ruling, a Federal Register notice or a form page.

  2. Attempted

    FinCEN began building the one dataset the Quote names that it does not already publish. On September 30, 2025 it proposed a new information collection, a Survey of the Costs of Anti-Money Laundering and Countering the Financing of Terrorism Compliance, seeking "information on the direct compliance costs incurred by non-bank financial institutions … with AML/CFT compliance requirements and, to the extent these expenses overlap with those of other activities (such as fraud monitoring), the amount attributable to AML/CFT compliance". What Congress has not done is require any of it to be published annually, which is the ask.

Research log

What was searched, and what didn’t count as evidence

Research notes

Leveled attempted under playbook §3b’s rule that executive action routing around a Requires-Congress ask is attempted: a one-off Paperwork Reduction Act collection is not an annual publication mandate, and it covers non-bank financial institutions only.

No bill in the 119th Congress would impose the publication requirement; the AML bills in the corpus are enforcement measures (S. 3801, H.R. 5877, S. 1339) or Congressional Review Act resolutions against individual FinCEN rules.

Corrected 2026-09-06 (read-queue ticket 07). The 2025-09-30 note said “FinCEN already publishes suspicious activity report and currency transaction report filing counts in its filing-trends data”. Half of that is wrong and the other half has stalled. There is no CTR filing-statistics page on fincen.gov; the published trend series is SAR-only, and it ends at calendar year 2024. The clause has been removed and the facts moved into the 2026-06-25 event.

Two route notes. fincen.gov/search/site?search=<anything> is a hard 404 for every term, nonsense and real alike (control: ctr%20filing%20statistics → 404 / 22,553 bytes; zzqqxnonsenseterm → 404 / 22,549) — it is useless rather than deceptive, but it is not a search. The enumeration route is fincen.gov/sitemap.xml, 2,876 URLs. And there are three parallel compliance-cost surveys, not one: FinCEN’s for non-bank financial institutions (FR 2025-18918, 2026-08242), the FDIC’s (2025-17593, 2026-00105) and the SEC’s (2025-20493, 2026-01306). Only FinCEN’s is this ask’s.

Action
issue
Object
FinCEN annual AML-CFT data publication
ID
1988