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Private banking software: price one enhanced KYC file first

Before comparing private banking software for KYC, price one enhanced source of wealth file from your own timesheets: reading, translation, re-keying, searches, the request, the narrative and the rework. No regulator or independent study publishes the figure, and the saving lives in those lines, not in the licence fee. This guide gives the worksheet, a worked estimate and where Source of Wealth Verification fits.

Updated · 12 min read

Private banking software covers a lot of ground, from core banking and portfolio management to client portals and CRM, but for KYC the question a buyer needs answered is narrow: what does one enhanced due diligence file cost today, line by line, and which lines can software remove? That file, proving how a high-risk client built their wealth and where the deposit comes from, is the slowest step in onboarding a private banking client, because the evidence arrives as share purchase agreements, probate records and tax returns in several languages, and an analyst reads, translates, re-keys and writes it up by hand. No regulator or independent study publishes what a file costs, so the business case has to start from your own timesheets. Botminds' Source of Wealth Verification is built for that one file: its agents read the evidence in any language, reconcile it to the declared net worth, test it and draft the request and the narrative, and three people sign. This page shows how to price the file before and after.

The worked estimate uses Botminds' own model for one high-risk client, and the solution's fictional sample firm. Replace both with your figures.

Where an enhanced file's working days go, by hand and with the agents

By hand · 9.5 business days

31.6%
21.1%
21.1%
15.8%
10.5%
  • Reading and translating · 31.6%
  • Searches · 21.1%
  • Narrative and rework · 21.1%
  • Re-keying · 15.8%
  • Request · 10.5%

With the agents · 1.0 business day

40%
20%
20%
10%
10%
  • Narrative and rework · 40%
  • Reading and translating · 20%
  • Searches · 20%
  • Re-keying · 10%
  • Request · 10%
Botminds' estimate for one high-risk client with evidence in two or three languages, in business days of analyst work; time waiting on the client is not counted. By hand: reading and translating 3, registry, plausibility and adverse media searches 2, narrative and checker rework 2, re-keying and reconciling 1.5, working out what is missing and writing the request 1. With the solution: 0.2, 0.2, 0.4, 0.1 and 0.1. An estimate, not a measured result; the one-day figure is the solution's design target.

Private banking software: price the enhanced file before the licence

A licence fee is the easiest number in a software decision and the least informative. The cost that software changes is the analyst time inside each enhanced file, and that is invisible until someone measures it. Pricing one file first does three things: it tells you which line items are large enough to matter, it gives you a baseline to hold a vendor to, and it shows which costs no software touches, such as the days a file waits for the client.

The regulators themselves do not count it. When FinCEN renewed its paperwork estimate for the US private-banking due diligence rule in 2024, it limited the estimate to maintaining and approving each institution's program, two hours a year per institution, and explained why it could go no further.

"Due to the practical challenges of obtaining the total number of correspondent accounts maintained by covered financial institutions … and the number of private banking accounts, the scope of the annual PRA burden is limited to the annual burden of (i) maintaining and updating a due diligence program …"

FinCEN, renewal of the information collection for 31 CFR 1010.610 and 1010.620, 89 FR 49273, 11 June 2024

What does an enhanced due diligence file cost?

The cost of an enhanced file is the analyst, checker and approver hours in it, times a loaded hourly cost, plus external costs such as translation and data, plus the rework when a file is returned. No regulator or independent study publishes a typical figure for source of wealth files, and figures quoted in marketing are vendors' surveys. The only defensible number is one built from your own files.

A worked example shows the method. Take Botminds' estimate of 9.5 business days of analyst work for a high-risk client with evidence in two or three languages, assume an eight-hour working day, and price the hours at the fully loaded composite hourly rate of $106.30 that FinCEN used in the same 2024 notice. That is 76 hours and about $8,080 of analyst time for one file by hand. At the solution's one-day design target it is 8 hours and about $850. The rate is not an analyst's wage: FinCEN built it from May 2022 national wage data for six occupations, chief executives and lawyers among them, scaled by a benefits factor of 1.42 (89 FR 49273). Use your own loaded cost for each role.

One file, priced: a worked estimate to replace with your own

76h

analyst hours for one high-risk file by hand: 9.5 business days at 8 hours, Botminds' estimate

$106.30

FinCEN's fully loaded composite hourly rate in its 2024 burden estimate

not an analyst wage

$8,080

analyst time per file by hand at that rate, before translation, data and the checker

$850

the same arithmetic at the solution's one-day design target

Our arithmetic: 9.5 × 8 × $106.30 = $8,079 and 1 × 8 × $106.30 = $850, rounded. The day estimate is Botminds' model for one high-risk client, not a customer's measured result; the rate is FinCEN's composite from 89 FR 49273 (June 2024).Source: FinCEN, 89 FR 49273

How long does a source of wealth review take?

No regulator publishes source-of-wealth review times, so the honest answer is to measure two different clocks. Working time is the hours someone is actually on the file. Elapsed time is the calendar from opening to decision, most of which is usually waiting: for the client, for a translation, for a checker. A file can take three weeks to close and contain four days of work.

Measure both from your case management or email timestamps on a sample of recent high-risk files: opened, first document received, last document received, submitted to checker, returned, approved. The gaps between timestamps show where the calendar goes; timesheets, or a week of analysts logging each file, show where the work goes. The fictional firm in the solution sets a service level of ten business days for a new-client file and two for the BSA/AML Officer's decision, and flags any file at risk of missing it.

Where do KYC analysts' hours go?

On a manual file, mostly into reading and re-keying rather than judgement. In Botminds' estimate, reading and translating foreign-language evidence takes about a third of the analyst's time, re-keying figures and reconciling them to declared net worth another sixth, and searches a fifth. Writing the narrative and handling the checker's rework take about a fifth, and working out what is missing and writing the request the rest. With agents doing the reading, re-keying and first drafts, the shape inverts: the largest share of a shorter day goes to the narrative and the checker's review, which is where judgement sits.

Source of Wealth Verification: the analyst's day starts with what was read overnight

Today screen for the sample KYC analyst, Monday, October 19, 2026, at the fictional firm. Tiles: needs you 5 (8 files are yours); open enhanced files 1,284 (23 at risk of missing the SLA); open document requests 146 (31 overdue with clients); with the BSA/AML Officer 7 high-risk decisions waiting. 'Needs you today', sorted by deadline: the sample client's probate record arrived Friday and the agents are ready to read it and close the $2.4M gap, due tomorrow; approve a draft request for exchange statements ($1.1M unexplained); a file returned by the checker for a sentence without a citation; a Portuguese news match proposed as a different person (91%); a trigger review for a $3.4M inflow from an undeclared account. Overnight: 212 documents read in 11 languages, 64 wealth histories rebuilt or updated, 1,906 news articles screened with 4 to confirm, 9 requests drafted, none sent.
Fictional sample data. The work the agents did overnight is counted, so the analyst's day is the five things that need a person, each with one action.

What is the cost of KYC per client? A worksheet for one enhanced file

Cost per client is a blend of cheap standard files and expensive enhanced ones, so price the enhanced file on its own. The worksheet below lists the lines to measure, how to measure each, and Botminds' estimate where one exists. Fill the right-hand column from a sample of your own recent files: twenty is enough to see the shape.

Cost-per-file worksheet for one enhanced source of wealth file

Line itemHow to measure itBotminds' estimate (days)Your figure
Reading and translating evidenceAnalyst hours on documents; translation invoices per file3.0 by hand · 0.2 with agentshours + $
Re-keying and reconciling to net worthHours on the spreadsheet; count of figures keyed1.5 · 0.1hours
Registry, plausibility and adverse media searchesHours, plus data and registry fees per file2.0 · 0.2hours + $
Working out what is missing, writing the requestHours, plus the count of request rounds per file1.0 · 0.1hours, rounds
Narrative and checker reworkAnalyst and checker hours; share of files returned2.0 · 0.4hours, % returned
ApprovalOfficer minutes per decision; files escalatednot estimatedminutes
Waiting on the clientElapsed days between request and replynot counteddays (no cost line, but it is the calendar)
Estimates from Botminds' model for one high-risk client with evidence in two or three languages. Multiply hours by each role's fully loaded cost; add external costs per file. The approval and waiting lines are where software saves least.

How many files can one analyst finish a week?

On Botminds' estimate, about one every two weeks by hand if an analyst did nothing else, and up to about five a week with the agents' reading and drafting done; in practice periodic reviews, trigger reviews and client queries take part of every week, so measure your own throughput rather than adopt either figure. The arithmetic is simply working days available divided by working days per file. What changes the result most is not the reading speed but the rework: a file returned by the checker, or sent back to the client a second time, costs the same hours again.

Volume decides whether the line items matter. The solution's fictional firm opened 540 enhanced files in one month, 318 for new clients, 184 periodic reviews and 38 trigger events, across New York, London and Singapore. Periodic reviews are lighter than new-client files, so a firm should price each type separately.

The volume a cost model has to carry: every enhanced file, with its gap and deadline

Enhanced files list at the fictional firm: 1,284 open and 540 opened this month (318 new clients, 184 periodic reviews, 38 trigger events) across New York, London and Singapore; a banner notes 212 new documents overnight and 23 files at risk of missing their service level, most waiting on clients. Each row shows client, type, risk score, stage and next step, net worth, unexplained amount and due date, with filters for stage, risk, booking centre, type and analyst.
Fictional sample data in Source of Wealth Verification. The unexplained column is the one a cost model forgets: every open amount is a request, a wait, or an escalation still to come.

What software cannot remove: waiting, deciding and bad requests

Three costs survive any tool. The first is the client's time: a request takes as long as the client takes to answer it, which is why the solution's sample firm counts 31 requests overdue with clients and why the estimate above excludes waiting. The second is decision time, which should stay with a person: the BSA/AML Officer's decision, the checker's review, the escalations. The third is rework caused by vague requests, which software only removes if it asks precisely.

The third is where regulators and cost meet. MAS's May 2026 circular tells firms to avoid "multiple rounds of information requests", and says a working group co-led by MAS under the Private Banking Industry Group was "established ... to improve account opening efficiency" (MAS Circular AMLD 05/2026). A file that goes back to the client once instead of three times saves the analyst's hours and the client's patience at the same time. How the agents draft that single request is in source of wealth checks.

What should private banking software do for KYC?

It should make the enhanced file faster without making it thinner. The cost of a thin file is not hypothetical: in 2012 Coutts was fined £8.75 million after the regulator found deficiencies in 73 of 103 high-risk files it reviewed (FSA Final Notice, 23 March 2012), and in August 2026 FinCEN's $125 million penalty against UBS Financial Services warned that risk-based due diligence is not "simply “papering” dispositions of apparent risks" (FinCEN, 3 August 2026). A tool that speeds up papering speeds up the finding.

What to ask private banking software before it touches a source of wealth file

  1. Show me one of our past files, end to end

    Use a closed high-risk file with foreign-language evidence. Time each line of the worksheet against your own record of it.

  2. Where does each figure come from?

    Every amount should open at its document and page, in the original language, with the translation beside it.

  3. What does it do with a gap?

    It should state the unexplained amount in money and name the document that would close it, not mark the file incomplete.

  4. Who can send a request to the client?

    Not an agent, and not the person who approved the request.

  5. What will the examiner get?

    One export per client: narrative, wealth history, every document with its reading, the tests, the request, the decisions and the policy in force.

  6. How are thresholds changed?

    By a person, with a second approval, re-tested on past decided files before the change goes live.

  7. Which of our systems does it replace?

    For this work, ideally none: it should read from onboarding, screening, CRM and custodian feeds, and write back decisions.

Our checklist for a buyer. The first question is the business case: if a vendor cannot run one of your closed files, the worksheet stays empty.

Where Source of Wealth Verification sits in a private banking stack

The solution is one part of the stack, not a replacement for it. It opens enhanced files from the risk model in the client onboarding system and returns decisions and conditions to it; takes sanctions, political-exposure and watchlist results from the screening service; reads news, court and regulatory articles from a multilingual news source and company filings and deal multiples from registry and financial data; sends client requests through the CRM; and reads inflows and holdings from core banking and custodian feeds. Originals are kept in the document archive with their seals and retention holds.

What the cost buys: one export the examiner can read without your systems

Audit trail screen with an export dialog for the sample file EDD-26-04417: one file a regulator or auditor can read without the firm's systems. Nine sections, all ticked: source-of-wealth narrative, version 2 with 22 citations; wealth history and reconciliation, $38.6M with streams, FX rates and dates; evidence, 14 documents, originals plus English readings, 371 pages; plausibility tests, 6 with benchmarks and sources; adverse media and political exposure, 545 articles in 3 languages, 1 cleared match; document requests, sent and answered; decisions and sign-off; audit trail; policy in force, KYC-POL-7.2 effective July 1, 2026. Format PDF with an index plus JSON; seal SHA-256. Behind it, the chained audit trail shows 88,438 entries verified since go-live.
Fictional sample data in Source of Wealth Verification. The examiner's file is assembled from what the agents and people already recorded, so building it is minutes, not a week of reconstruction.

It does not hold assets, book trades, run portfolios, screen names, monitor transactions or decide which clients are high risk. If your KYC cost is mostly in standard onboarding of low-risk clients, a client onboarding platform is the better first purchase, and choosing client onboarding software covers that work. If it is in enhanced files with foreign-language evidence, the worksheet above will show it, and the source of wealth checklist sets out what to prepare before go-live. The Source of Wealth Verification page shows the full sample file, and who signs the file covers the three signatures the cost model should never remove.

Questions people ask

What is private banking software?

A broad term for the systems a private bank runs: core banking and custody, portfolio management, client onboarding and KYC, CRM and client portals. For KYC buyers, the useful distinction is between onboarding platforms that collect standard information and tools for the enhanced file that proves source of wealth for high-risk clients.

Is there an industry benchmark for KYC cost per client?

Not from a regulator or an independent study for source of wealth files; FinCEN's own burden estimate for US private-banking due diligence counts program maintenance only, because the number of accounts could not be obtained. Build the figure from a sample of your own files.

Which part of the file costs most by hand?

In Botminds' estimate, reading and translating foreign-language evidence, about three of nine and a half business days, followed by searches and by the narrative with its rework. Your mix will depend on how much of your clients' evidence is in English.

Does faster onboarding mean weaker due diligence?

Not if the time saved is reading and re-keying rather than checking and deciding. MAS's 2024 circular asks firms to minimise "any undue delay to the onboarding of legitimate customers" while corroborating the material sources; the saving should come from the mechanical lines, with the checker and approver steps intact.

How do I build the business case?

Price twenty recent high-risk files with the worksheet, multiply by annual volume per file type, and compare with a vendor's run on a few of the same files. Count the returned files and repeat requests separately; they are often the largest saving.

Source of Wealth Verification.
See it on your own files.

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