KYC, AI & the Balancing Act: Inside the Compliance Frontline

One of the standout discussions on Day 1 was titled “KYC: Balancing Compliance and CX”, attended by a group of Chief Compliance Officers, Heads of Fraud and MLROs, spanning land-based casinos, high street betting shops, and online operators. The discussion provided a valuable cross-channel perspective on how Know Your Customer (KYC) requirements are being interpreted and implemented across very different operating environments.

A key theme that emerged was the inconsistency in UK KYC regulation and application across verticals. Online operators are often able to capture limited identification data at the first customer interaction and throughout the customer journey, whereas betting shops and land-based casinos often benefit from free footfall, with KYC data only being triggered once certain wagering thresholds are met. This disparity continues to create operational complexity and an uneven compliance landscape.

Another major area of discussion was the rapid impact of AI on fraud, compliance, and detection capabilities. Attendees highlighted that criminals and bad actors are increasingly leveraging AI to enhance the sophistication of fraud attempts, while many operators are still working to adapt their prevention and detection tools at the same pace. This has created an ongoing capability gap that organisations are actively trying to close.

At the same time, there was clear recognition that AI adoption must be balanced with human oversight. Operators emphasised the importance of ensuring that key risk decisions remain human-led at appropriate points in the customer journey. Rather than fully automating decisions, the focus is on introducing targeted friction where necessary to protect against financial crime—such as requiring enhanced verification, documentation, or even face-to-face engagement for higher-risk customers.

The roundtable also explored evolving best practice around Source of Wealth (SoW) and Source of Funds (SoF). Participants agreed that effective assessment goes beyond reviewing isolated documents such as bank statements. Instead, stronger approaches consider broader financial behaviours, including income and expenditure patterns, to build a more complete and accurate risk profile.

Finally, a strong governance theme ran throughout the discussion. Attendees highlighted the importance of closer alignment between Compliance and Commercial teams, with governance frameworks that support transparency in decision-making. The goal is to reduce friction between departments, minimise unnecessary back-and-forth, and ensure that compliance is embedded as a strategic partner rather than a downstream function.

The value of these insights was significantly enhanced by the peer-led roundtable format, conducted under Chatham House Rule. This created a trusted environment where participants could speak openly and honestly about real-world challenges, share operational experiences, and discuss opportunities without attribution. The result was a highly candid and constructive dialogue that would be difficult to replicate in more formal, presentation-led settings.

Overall, the session reinforced the importance of bringing industry leaders together in a structured but open forum. Peer-led roundtables continue to prove their value in surfacing practical insight, enabling honest benchmarking, and driving more informed thinking across the payments, fraud, and compliance landscape in gaming.

Author: Garikai Mparutsa | Director | Deloitte LLP