Teardown · November 2023 · Identity verification
Built as a case study exercise using public information. Not a client engagement.
Sumsub: selling KYC into European gambling, where the regulator is also a buyer
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.
3
Buyers addressed
11%
Market CAGR
4
Competitors assessed
The analysis in three numbers.
What I built
A go-to-market covering three distinct ICPs (gambling operators, financial institutions and regulatory bodies), each with its own personas, goals, pains, value framing, message and channel mix.
Operators get accelerate onboarding without compromising compliance. Financial institutions get secure your operations and mitigate transactional risk. Regulators get strengthen oversight and foster a safer environment, reached through roundtables, collaborative research and policy-maker engagement rather than demos and digital advertising.
A competitive assessment against Jumio, Onfido, Trulioo and Veriff, positioning Sumsub on whole-journey coverage, customisability and global reach with local expertise.
Then a second act: adoption strategy for non-doc verification. Upsell to customers in non-doc territories (Argentina, Bangladesh, Brazil, Ghana, India, Indonesia, Netherlands, Nigeria, the UK), and cross-sell to existing KYC, AML and KYT customers, 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.
The judgment call
Treating the regulator as a buyer with a budget for attention.
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's exactly why it's available.
What I'd do differently
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.