Frequently asked questions.

Fully-loaded onboarding cost typically falls £4-£18 for a low-risk retail customer, £24-£78 for an EMI corporate customer, and £45-£180 for a high-risk EDD customer. The vendor invoice line is usually 35-55% of the total; ops labour, screening cycles and EDD overlay account for the rest. Volume materially affects the figure: under 10,000 onboardings a year, expect £28-£75; above 100,000 onboardings, expect £6-£18 per customer fully loaded.

Simplified due diligence (SDD) costs roughly £2-£8 per customer fully loaded; standard customer due diligence (CDD) costs £4-£18; enhanced due diligence (EDD) adds £25-£90 on top of the CDD baseline for a fully-loaded total of £35-£140 per high-risk customer. EDD typically costs 3-8x CDD because of senior-management approval bottlenecks, source-of-funds review, UBO mapping for cross-border chains, and enhanced adverse media review.

It is usually bundled into the platform price as a per-cycle line item. Procurement teams should require sanctions screening to be broken out as a discrete line in the vendor commercials. Per-cycle vendor pricing typically £0.05-£1.20 depending on data provider scope and volume tier; the labour cost of investigating the 0.5-3% hit rate the cycles generate is a separate (and often larger) line.

LSEG / Forrester True Cost of AML Compliance places the average annual KYC and AML spend at large institutions at $72.9M, cited via FNZ, Fenergo and Lucinity. Mid-sized fintechs spend materially less in absolute terms but typically more as a share of operating cost (15-25% vs 8-12% at large institutions). The KYC share of total financial-crime compliance is typically 30-45%.

Fintechs typically run higher per-customer KYC cost than traditional retail banks because their customer-acquisition motion is more digital and false-positive friction destroys CAC unit economics. Traditional banks absorb friction into existing relationship infrastructure. Fintechs over-index on automation investment and tooling cost; banks over-index on labour scale.

A pKYC-migrated 50,000-active-customer fintech typically lands at £550,000-£700,000 annual recurring KYC cost, vs £900,000-£1,100,000 on traditional periodic review. The £300,000-£400,000 annual saving pays back a £100,000-£200,000 implementation cost within 6-12 months. Below 50,000 active customers the implementation cost typically dominates the saving.

Crypto exchanges typically run 15-40% EDD population versus 3-7% for retail challenger banks. Source-of-funds verification dominates per-customer cost. EU MiCA Regulation and UK FCA cryptoasset firm registration both tighten the baseline further. Fully-loaded per-customer KYC for a crypto exchange typically lands £45-£180; for a retail challenger bank £8-£22. The product-mix risk profile is the dominant variable.

Compare the per-check rate to public ComplyCube and Sumsub anchors ($0.10-$1.50 ID document, $0.25-$2.00 biometric, $1.35 Sumsub reusable verification). Add screening cycles, EDD overlay weighted by your high-risk population, and ops labour weighted by your hit rate. The gap between the vendor invoice and fully-loaded per-customer cost is typically 60-120%; if a vendor quote ignores that gap, the budget will overrun mid-year.

No. The FCA Handbook (SYSC 6.3) sets systems-and-controls expectations and the Money Laundering Regulations 2017 set the statutory framework, but neither prescribes a cost level. Cost levels are commercial decisions on the firm; supervisory expectations are about effectiveness, recordkeeping and proportionality. JMLSG Guidance gives the sectoral interpretation that supervisors use to evaluate firms.

Volume-discount mechanics typically reduce vendor commercials 30-50% from the under-10,000 bracket to the 100,000+ bracket. Step-tiers commonly sit at 10,000, 50,000, 250,000 and 1,000,000 verifications per year. Ops labour, by contrast, scales roughly linearly with onboarding volume. Net effect: fully-loaded per-customer cost typically falls from £28-£75 in the under-10,000 bracket to £6-£18 in the 100,000+ bracket.

Match the verification depth to the risk profile (FATF-aligned, MLR 2017-compliant SDD where supportable). Use a single primary vendor on a committed-use contract. Build workflow / decisioning / case management in-house above the volume crossover. Invest in adverse-media triage automation above 100,000 onboardings a year. Avoid double-paying for sanctions data the platform already includes. Maintain a defensible risk assessment so SDD is supportable to a supervisor.

Recurring. Onboarding KYC is a one-time per-customer cost; ongoing monitoring (refresh, continuous screening, perpetual KYC) is an annual recurring line that scales with active book size, not new onboardings. For a mature fintech the annual recurring line typically exceeds the annual onboarding line. The two are budgeted separately.