Sanctions, PEP and adverse media: the line vendors bundle and finance teams miss.
Vendor pricing routinely rolls sanctions screening into the platform price. Procurement and finance teams need it broken out to compare quotes, to size labour cost, and to model the hit-rate × investigation-cost line that determines true screening spend.
Per-cycle vendor: £0.05 - £1.20 | Hit rate: 0.5 - 3% | Annual screening line for 100k book: £80k - £300k
Why this is a separate budget line.
The vendor invoice shows screening as part of the platform commercial. The procurement team sees one number. The finance team builds a budget from that one number. Six months later the ops team is paying for analyst time that nobody allocated, because the platform cost did not include the labour to investigate the 0.5-3% sanctions / PEP / adverse media hits that the cycles generate.
Surfacing screening as a discrete line forces the question of investigation labour into the budget conversation at the time it can still be sized. The page below sets out the four pricing components: per-cycle vendor cost, data feed licence, hit-rate × investigation labour, and continuous-monitoring multiplier.
Per-cycle vendor cost.
| Configuration | Per-cycle low | Per-cycle high | Notes |
|---|---|---|---|
| OFAC SDN only | £0.05 | £0.40 | US-only firms; narrowest list scope. |
| OFSI UK consolidated | £0.10 | £0.55 | UK firms; HMT-published list, daily refresh requirement. |
| EU consolidated + OFSI | £0.20 | £0.85 | Multi-jurisdictional EU and UK firms. |
| UN consolidated + multi | £0.25 | £1.00 | Cross-border fintechs; broad jurisdictional scope. |
| Multi-list + PEP + adverse media | £0.40 | £1.20 | Standard fintech configuration; full data feed scope. |
Sources: ComplyCube and Sumsub published per-cycle commercials (2025); ComplyAdvantage, Acuris and RDC published industry tier benchmarks; engagement-history triangulation. Volume discount mechanics typically reduce the upper bound 30-50% above 250k cycles per year.
Onboarding screening vs continuous screening.
Onboarding screening runs once: customer plus beneficial owners against the configured list scope. Continuous screening runs on an ongoing cadence (daily, weekly or monthly) against list changes. Continuous screening is the materially larger annual line because it scales with active book size, not new onboardings.
For a 100,000-customer active book at £0.50 per cycle on a weekly cadence, the continuous screening line is roughly £2.6M per year on vendor commercials alone, before any labour. Most firms negotiate a flat-fee continuous-screening tier above 100k customers; the per-cycle equivalent typically falls to £0.10-£0.30 at that volume. See the ongoing cost page for the full annual line.
Hit rate × investigation cost = the real screening line.
Sanctions and PEP hit rates of 0.5-3% on retail customers, 5-15% on higher-risk segments. Each hit triggers ops labour: 6-25 minutes investigation at £18-£28/hour fully-loaded UK junior analyst rate, with senior MLRO escalation on the small percentage that need it (£85-£180/hour, 30-90 minutes per case).
The product hit-rate × investigation-cost typically dominates the per-customer screening line. A 4% hit rate at £6.50 average investigation cost = £0.26 of pure ops labour per onboarded customer, often more than the per-cycle vendor cost itself. See the false-positive cost page for the full FTE sizing model.
Adverse media is the cost amplifier.
Sanctions hits are rare and binary; PEP hits are more frequent but largely binary; adverse media hits are frequent and ambiguous. A typical adverse media alert needs a human to read the article, judge whether the customer is the subject of the article, and judge whether the activity described constitutes a meaningful AML or reputational concern. The labour cost per adverse-media alert is consistently the highest of the three categories.
Industry benchmarks place adverse media false-positive rates above 90% on legacy keyword-matching systems; AI-assisted triage typically reduces false positives 60-70% (Lucinity, LSEG, ACAMS commentary). Where the firm operates at scale, adverse media triage is the single highest-leverage automation investment.
Geographic scope and the cost implication.
HMT-published; daily refresh expectation under JMLSG Guidance.
AMLR transitional regime through 2027; AMLA centralisation upcoming.
Narrower list scope, but state-level layers add cost in money services.
Cross-border fintechs carry the full scope; data feed cost compounds.
FATF grey-list and black-list jurisdictions trigger enhanced ongoing screening for relationships with persons established in those jurisdictions. The FATF list is updated three times yearly; firms must check at every plenary. See the geography page for the per-jurisdiction cost picture.
Sanctions screening cost questions
How much does sanctions screening cost?+
Is sanctions screening included in standard KYC vendor pricing?+
What is the cost of OFAC screening?+
How often must sanctions screening run?+
What does adverse media screening add?+
Which data provider should we use?+
Sources cited on this page
- OFSI UK consolidated sanctions list
- EU consolidated financial sanctions list
- OFAC Specially Designated Nationals list
- FATF jurisdictions under increased monitoring (grey list)
- JMLSG Guidance Part I current edition
- ComplyCube and ComplyAdvantage published per-cycle commercials
- Lucinity AML labour-cost commentary on adverse media false positives