![Why AML in payments needs agility and localisation in frontier markets By Rachael Kennedy - July 29, 2025 Share A digital world map or globe with glowing payment network lines connecting different regions (particularly Africa, Southeast Asia, Eastern Europe, representing AML in payments Image: SBC Media SBC Summit AML in payments must evolve to address fragmented regulation, localised risk, and underdeveloped infrastructure. FDJ United’s Olena Demchenko shares her insights ahead of SBC Summit Lisbon. As digital payments expand into high-growth and frontier markets, compliance leaders face a delicate balancing act. Financial inclusion, transaction speed and user convenience often run up against fragmented regulation, underdeveloped infrastructure and fast-evolving criminal tactics. Ahead of her appearance at SBC Summit Lisbon, Olena Demchenko, Head of AML at FDJ United, spoke to Payment Expert to share her views on how the industry can adapt. With experience across regulated markets and an eye on emerging regions, she argues that agility, localisation and cross-sector collaboration are critical to developing scalable AML strategies. Fragmented regulation challenges long-term planning Despite efforts to harmonise AML rules across Europe, Demchenko warns that fragmentation remains a serious operational challenge. “A significant underestimated challenge is the lack of a standardised regulatory framework within the EU,” she said. “Even though AML regulations within the EU are on the path of standardisation, regulatory compliance requirements within the gambling industry remain fragmented due to the public policy of each Member State.” This complexity is particularly acute in younger markets where regulation is still maturing. “The swift evolution of regulations can outpace local infrastructure development, forcing companies into a reactive compliance posture,” she added. For businesses looking to grow across borders, she advises investment in regulatory intelligence and proactive engagement with local authorities to support long-term planning. Innovation under constraint In markets where digital infrastructure remains underdeveloped, compliance cannot rely on plug-and-play systems. Instead, Demchenko stresses the importance of drawing on global experience and tailoring tools to local conditions. “Balancing compliance and innovation in regions with underdeveloped digital infrastructure requires leveraging global experience from other markets,” she said. “This involves streamlining KYC processes, transaction monitoring, and payment ownership verification, and employing adaptable technologies that function effectively in limited environments.” Profile photo of Olena Demchenko Olena Demechenko, Head of AML, FDJ United She added that frontline training and long-term partnerships between operators and payment service providers are also vital to building solutions that work ahead of regulatory changes. Offline-first wallets raise red flags The rise of offline-first wallets in low-connectivity regions may support financial access, but Demchenko is clear about the compliance risks they carry. “Such solutions create a risk of traceability of payment transactions, reportability of suspicious activity, [and] can complicate CDD checks,” she explained. “Possible usage of offline-based payments within the gambling industry would require significant investments both from operator and provider perspectives to ensure robust internal AML controls.” She notes that offline solutions may find a niche, but success depends on rigorous customer identification, regular audits and direct collaboration with regulators. Trust is built through localisation While language localisation is a basic step in entering new markets, Demchenko believes the real value lies in understanding local payment behaviours and money laundering typologies. “Successfully onboarding users in high-growth markets requires a nuanced approach that respects local customs, preferences, and regulatory environments,” she said. “Different markets may present unique risks and patterns of illicit activity.” She points to region-specific risk assessments and tailored AML controls as the best way to enhance compliance while building trust with local users. Real-time tech sharpens response The adoption of real-time APIs has transformed how compliance teams respond to threats. For high-volume environments such as gambling, speed is critical. “Real-time APIs significantly enhance AML efforts by enabling instantaneous monitoring and transaction analysis,” said Demchenko. “It can help the operator to focus on prevention rather than post-factum detection and reporting.” She noted that such systems are essential in identifying behaviours like smurfing, churning and high-velocity transactions, enabling operators to block threats before damage is done. Fintechs and banks must align The line between fintech innovation and traditional banking is blurring as both sides recognise the value of collaboration in fighting financial crime. “Fintechs more often utilise AI and machine learning for enhanced transaction monitoring, income categorisation, and fraud detection,” Demchenko explained. “At the same time, many payment solution providers rely on the quality of bank data and invest in cooperation and integration with traditional financial institutions.” She highlights the complementary value of OSINT and HUMINT, suggesting data sharing between fintechs and banks can lead to stronger, more accurate KYC processes in emerging markets. Mature markets can learn from the edge While frontier economies are often seen as high-risk, Demchenko believes they offer valuable lessons in how to balance speed and safety. “Mature markets can learn the value of agility in adopting new technologies and the need for a balanced approach between regulation and innovation,” she said. “Frontier economies often demonstrate how quickly fintechs implement solutions like mobile wallets that cater to local preferences.” She argues that regulatory streamlining, coupled with advanced technologies like NFC-based ID verification and AI-led risk assessments, can help established markets innovate without compromising compliance. Demchenko’s panel at SBC Summit Lisbon will focus on the role of technology in AML transformation. She believes it is an urgent conversation for both gambling operators and payment providers. “As the financial world continues to evolve, leveraging advanced technologies such as artificial intelligence, machine learning, and data analytics becomes increasingly vital in identifying suspicious activities and adhering to regulatory requirements,” she said. “Embracing technological innovation in AML compliance will not only protect businesses but also contribute to a more secure financial ecosystem as a whole.” SBC Summit will take place from 16–18 September at the Feira Internacional de Lisboa and MEO Arena, bringing together 30,000 industry stakeholders for an unmissable three-day experience. Looking to attend? Here’s how: Secure your place with a VIP Event Pass – Enjoy full access to all conference sessions, the exhibition floor, exclusive networking events, and complimentary food and drink throughout the summit. Bringing the team? Take advantage of our Group Pass Discount — purchase three or more VIP Event Passes and pay just €400 per ticket (saving €200 off the standard price). Operator or affiliate? You may be eligible for a complimentary VIP Event Pass, which includes full access to the exhibition, conference, and exclusive networking events. Apply now to reserve your spot. Expo+ Pass: Gain access to the full exhibition floor and all conference sessions across the three days. This does not include access to our exclusive VIP evening networking events.](https://storage.sbcevents.com/assets/2025/07/aml-payments-localisation.png)
AML in payments must evolve to address fragmented regulation, localised risk, and underdeveloped infrastructure. FDJ United’s Olena Demchenko shares her insights ahead of SBC Summit Lisbon.
As digital payments expand into high-growth and frontier markets, compliance leaders face a delicate balancing act. Financial inclusion, transaction speed and user convenience often run up against fragmented regulation, underdeveloped infrastructure and fast-evolving criminal tactics.
Ahead of her appearance at SBC Summit Lisbon, Olena Demchenko, Head of AML at FDJ United, spoke to Payment Expert to share her views on how the industry can adapt.
With experience across regulated markets and an eye on emerging regions, she argues that agility, localisation and cross-sector collaboration are critical to developing scalable AML strategies.
Fragmented regulation challenges long-term planning
Despite efforts to harmonise AML rules across Europe, Demchenko warns that fragmentation remains a serious operational challenge.
“A significant underestimated challenge is the lack of a standardised regulatory framework within the EU,” she said. “Even though AML regulations within the EU are on the path of standardisation, regulatory compliance requirements within the gambling industry remain fragmented due to the public policy of each Member State.”
This complexity is particularly acute in younger markets where regulation is still maturing. “The swift evolution of regulations can outpace local infrastructure development, forcing companies into a reactive compliance posture,” she added.
For businesses looking to grow across borders, she advises investment in regulatory intelligence and proactive engagement with local authorities to support long-term planning.
Innovation under constraint
In markets where digital infrastructure remains underdeveloped, compliance cannot rely on plug-and-play systems. Instead, Demchenko stresses the importance of drawing on global experience and tailoring tools to local conditions.
“Balancing compliance and innovation in regions with underdeveloped digital infrastructure requires leveraging global experience from other markets,” she said. “This involves streamlining KYC processes, transaction monitoring, and payment ownership verification, and employing adaptable technologies that function effectively in limited environments.”
She added that frontline training and long-term partnerships between operators and payment service providers are also vital to building solutions that work ahead of regulatory changes.
Offline-first wallets raise red flags
The rise of offline-first wallets in low-connectivity regions may support financial access, but Demchenko is clear about the compliance risks they carry.
“Such solutions create a risk of traceability of payment transactions, reportability of suspicious activity, [and] can complicate CDD checks,” she explained. “Possible usage of offline-based payments within the gambling industry would require significant investments both from operator and provider perspectives to ensure robust internal AML controls.”
She notes that offline solutions may find a niche, but success depends on rigorous customer identification, regular audits and direct collaboration with regulators.
Trust is built through localisation
While language localisation is a basic step in entering new markets, Demchenko believes the real value lies in understanding local payment behaviours and money laundering typologies.
“Successfully onboarding users in high-growth markets requires a nuanced approach that respects local customs, preferences, and regulatory environments,” she said. “Different markets may present unique risks and patterns of illicit activity.”
She points to region-specific risk assessments and tailored AML controls as the best way to enhance compliance while building trust with local users.
Real-time tech sharpens response
The adoption of real-time APIs has transformed how compliance teams respond to threats. For high-volume environments such as gambling, speed is critical.
“Real-time APIs significantly enhance AML efforts by enabling instantaneous monitoring and transaction analysis,” said Demchenko. “It can help the operator to focus on prevention rather than post-factum detection and reporting.”
She noted that such systems are essential in identifying behaviours like smurfing, churning and high-velocity transactions, enabling operators to block threats before damage is done.
Fintechs and banks must align
The line between fintech innovation and traditional banking is blurring as both sides recognise the value of collaboration in fighting financial crime.
“Fintechs more often utilise AI and machine learning for enhanced transaction monitoring, income categorisation, and fraud detection,” Demchenko explained. “At the same time, many payment solution providers rely on the quality of bank data and invest in cooperation and integration with traditional financial institutions.”
She highlights the complementary value of OSINT and HUMINT, suggesting data sharing between fintechs and banks can lead to stronger, more accurate KYC processes in emerging markets.
Mature markets can learn from the edge
While frontier economies are often seen as high-risk, Demchenko believes they offer valuable lessons in how to balance speed and safety.
“Mature markets can learn the value of agility in adopting new technologies and the need for a balanced approach between regulation and innovation,” she said. “Frontier economies often demonstrate how quickly fintechs implement solutions like mobile wallets that cater to local preferences.”
She argues that regulatory streamlining, coupled with advanced technologies like NFC-based ID verification and AI-led risk assessments, can help established markets innovate without compromising compliance.
Demchenko’s panel at SBC Summit Lisbon will focus on the role of technology in AML transformation. She believes it is an urgent conversation for both gambling operators and payment providers.
“As the financial world continues to evolve, leveraging advanced technologies such as artificial intelligence, machine learning, and data analytics becomes increasingly vital in identifying suspicious activities and adhering to regulatory requirements,” she said.
“Embracing technological innovation in AML compliance will not only protect businesses but also contribute to a more secure financial ecosystem as a whole.”
SBC Summit will take place from 16–18 September at the Feira Internacional de Lisboa and MEO Arena, bringing together 30,000 industry stakeholders for an unmissable three-day experience.
Looking to attend? Here’s how:
- Secure your place with a VIP Event Pass – Enjoy full access to all conference sessions, the exhibition floor, exclusive networking events, and complimentary food and drink throughout the summit.
- Bringing the team? Take advantage of our Group Pass Discount — purchase three or more VIP Event Passes and pay just €400 per ticket (saving €200 off the standard price).
- Operator or affiliate? You may be eligible for a complimentary VIP Event Pass, which includes full access to the exhibition, conference, and exclusive networking events. Apply now to reserve your spot.
Expo+ Pass: Gain access to the full exhibition floor and all conference sessions across the three days. This does not include access to our exclusive VIP evening networking events.
Source: https://paymentexpert.com/2025/07/29/aml-in-payments-localisation-frontier-markets/
