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

Compliance Fintech & Payments

The situation

Compliance software has an unusual problem: the people who buy it, the people who mandate it and the people who are protected by it 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

5 of 34 outputs

Research

Competition

Segment, position and price

Message

Launch and enable

Measure and maintain

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

02 · The decision

Treat 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 exactly why it was available.

03 · What I wasn't given

Customer interviews

Products in one brief

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.

01Size the market and read the 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, rather than features, 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 rather than demos and digital advertising

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, knowing it was the part most likely to be argued with.

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 is a channel that gets cut in the first budget 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 rather than campaigns. 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 The Fifty is built to be re-run rather than written once.

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

Customer interviews

Products in one brief

Non-doc territories

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

Set by the company.