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Identity verification · Europe · 2023

Sumsub: selling KYC into European gambling, where the regulator is also a buyer

SECTOR

Identity verification, KYC

MARKET

Europe

COMPANY

Sumsub

ROLE APPLIED FOR

Senior PMM

DATE

Nov 2023

ComplianceFintech & Payments

The situation

Compliance software has an unusual problem: the people who buy it, the people who mandate it and the people it protects are three different audiences with three different definitions of success.

European online gambling was growing at 11% CAGR with the UK taking 65% of it, under regulatory frameworks that were tightening on player protection, advertising and data privacy simultaneously.

Most identity-verification vendors sell to one buyer: the operator's compliance officer. That leaves the two other parties in the room unaddressed.

01 · What this engagement produced

10 of 34 outputs

10 of the 34 outputs, across five of the six stages.

01Research2 of 6
03Market report04Why now

4 not produced

Voice of customer, Win / loss, Assumption log, Pre-mortem

02Competition2 of 4
07The Fifty08Table-stakes read

2 not produced

AI visibility, Competitor monitor

03Segment, position and price3 of 6
11ICP and segments13Buying committee14Positioning

3 not produced

Use cases, Packaging and pricing, Deck spine

04Message1 of 4
17Messaging framework

3 not produced

Claim check, Landing page review, Message drift

05Launch and enable2 of 8
22Launch brief23Channel and funnel

6 not produced

Launch tiers, Product Oracle, Sales enablement, FAQ, Onboarding journey, Release notes

06Measure and maintain0 of 6

6 not produced

Product funnel metrics, Launch post-mortem, Trust metrics, Customer case studies, Half-Life Map, Six-stage readout

Solid is what the brief produced. Dashed is what it did not reach, and could not from outside.

02 · The decision

I treated the regulator as a buyer with a budget for attention.

Compliance software has an unusual problem: the people who buy it, the people who mandate it and the people protected by it are three different audiences with three different definitions of success. Most identity-verification vendors sell to one of them, the operator's compliance officer, and leave the other two unaddressed.

Regulators don't purchase your software. But in a licensed market they shape which vendors an operator can defensibly choose, and they are reachable, through research, roundtables and policy engagement, by anyone willing to invest in a channel that produces no attributable pipeline.

Most vendors won't, because it doesn't show up in the funnel. That is why it was available.

03 · What I wasn't given

0

Customer interviews

2

Products in one brief

9

Non-doc territories

Not givenNo access to their pipeline, their win rates or a single customer.

04 · The work

4 moves

Three buyers, then a second product.

01Market size and regulation

01 Research

  • European online gambling growing at 11% CAGR, with the UK taking 65% of it
  • Regulatory frameworks tightening simultaneously on player protection, advertising and data privacy, three separate pressures arriving at the same compliance officer
  • Which makes timing the argument that opens the conversation
02Three ICPs

03 Segment, position & price

  • Gambling operators, financial institutions and regulatory bodies, each with its own personas, goals, pains, value framing and channel mix
  • Operators: accelerate onboarding without compromising compliance
  • Financial institutions: secure your operations and mitigate transactional risk
  • Regulators: strengthen oversight and foster a safer environment, reached through roundtables, collaborative research and policy-maker engagement
03The competitive read

02 Competition

  • Assessed against Jumio, Onfido, Trulioo and Veriff
  • Positioned on whole-journey coverage, customisability, and global reach with local expertise
  • Those three matter most to an operator holding licences in several jurisdictions at once, which is the shape of the buyer this segment produces
04The second act: non-doc adoption

05 Launch & enable

  • Upsell into the nine territories where non-documentary verification is viable: Argentina, Bangladesh, Brazil, Ghana, India, Indonesia, the Netherlands, Nigeria and the UK
  • Cross-sell into the existing KYC, AML and transaction-monitoring base
  • Split by regulated versus unregulated industry with a different value message for each: maximise conversion and cut operational cost for regulated, speed and flexibility for unregulated

Where I pushed back

The brief asked for a go-to-market. I put a channel with no attributable pipeline into it.

Everything about a regulator channel is uncomfortable to propose in an interview. Long lead time, no demo, no attribution, no obvious owner. A panel can reasonably ask why a product marketer is proposing policy engagement.

The answer is that in a licensed market the regulator sets the frame every compliance officer buys inside. Ignoring the person who defines defensible is a strange way to sell defensibility. So it went in, and I knew the panel was most likely to argue with it.

05 · What I'd change

The regulator strategy has no measurement model attached, and I should have built one, even a crude leading indicator like citations in consultation documents. A channel with no metric loses its budget at the first review, however right it is.

What happened next

HELD UP

Both halves of the brief became product lines.

Nov 2023

I presented this. Non-doc verification was a feature to drive adoption of, and gambling was one vertical among many.

Apr 2024

Entrust completed its acquisition of Onfido, one of the four competitors I assessed, reportedly for well above $400 million. Entrust

Today

Sumsub runs a dedicated iGaming page covering KYC, AML, fraud prevention and transaction monitoring, and a separate product page for non-documentary verification. sumsub.com

The two things the brief asked me to connect, a gambling vertical and non-doc adoption, are both now standing parts of the company's public positioning. That is the outcome you want from a segment argument: it stops being a campaign and becomes a page.

The competitive set aged faster than the strategy. One of the four names I assessed no longer exists as an independent company. That is the ordinary half-life of a competitive grid, and the reason I built The Fifty to be re-run.

The brief, as it was set

Brief set by Sumsub

November 2023

Senior PMM, take-home

Take our identity verification product into the European gambling market. Define the ICPs, the messaging and the go-to-market, and show how you'd drive adoption of non-doc verification alongside it.

Summarised from the brief. Answered from public regulatory and market sources only.

What I wasn't given

0

Customer interviews

2

Products in one brief

9

Non-doc territories

Not givenNo access to their pipeline, their win rates or a single customer.

Set by the company.