Q&A: Luis Carlos Pérez emphasises AML judgment for gaming clients

As anti-money laundering frameworks continue to evolve globally, payment and compliance professionals serving the gaming sector face increasingly complex challenges in identifying and managing high-risk customers. Luis Carlos Pérez, speaking ahead of the SBC Summit Lisbon conference scheduled for late September through early October 2026, highlighted the critical importance of applying informed judgment rather than relying solely on automated systems when evaluating gaming clients.

The gaming industry occupies a unique position within AML regulatory frameworks. Gaming operators handle large volumes of cash transactions, process rapid customer fund movements, and operate across multiple jurisdictions with varying regulatory standards. This operational complexity creates inherent challenges for AML teams tasked with distinguishing between legitimate high-value gaming activity and potentially suspicious patterns. Pérez's emphasis on judgment reflects recognition that rule-based systems, while necessary, cannot capture the contextual nuances that distinguish legitimate gaming behavior from genuine money laundering risk.

Continuous AML oversight represents an emerging best practice within the sector. Rather than conducting point-in-time risk assessments, operators increasingly implement ongoing monitoring systems that track customer behavior throughout their relationship with the operator. Payment data analysis plays a central role in this approach, enabling AML teams to identify anomalies, sudden behavioral changes, or patterns inconsistent with a customer's established profile. For gaming operators, this means analyzing not only transaction amounts and frequencies but also the relationship between gaming activity, deposits, withdrawals, and fund sources.

The challenge intensifies when operators serve customers across multiple jurisdictions or payment methods. Different regulatory regimes impose varying requirements for customer due diligence, beneficial ownership verification, and transaction reporting thresholds. Payment experts must navigate these differences while maintaining consistent risk management standards. Pérez's perspective suggests that experienced judgment—informed by regulatory knowledge, industry patterns, and individual customer context—remains essential despite technological advances in transaction monitoring.

For gaming operators preparing for SBC Summit Lisbon discussions, the takeaway emphasizes that effective AML compliance requires balancing regulatory compliance with operational pragmatism. Operators that invest in experienced compliance personnel capable of exercising informed judgment while leveraging payment data analytics will likely achieve superior outcomes in both risk mitigation and customer experience.