Case Study

The Challenge

Perform Partners, alongside Betsmart Consulting, supported a regulatory-driven anti–money laundering (AML) and know-your-customer (KYC) vendor migration for a UAE-based client operating national lottery and iGaming platforms (i.e., regulated digital gaming environments covering lottery draw products and online betting/casino services).

The client was required to replace ComplyAdvantage with Crucial Compliance as its AML/KYC provider. These platforms deliver AML and KYC capabilities, including identity verification, sanctions and politically exposed person (PEP) screening, transaction monitoring, and ongoing risk profiling to ensure compliance with financial crime regulations.

The migration was necessary to meet updated regulatory requirements and to replace an expiring contract with ComplyAdvantage. The transition had to be delivered in line with a fixed milestone for the broader lottery platform migration, ensuring there was no disruption to player onboarding, verification processes, or regulatory reporting.

The engagement covered two workstreams:

• Migration of the live lottery platform
• Definition of a compliant transition approach for the iGaming platform

Success was defined by completing the lottery platform migration by the contractual deadline with no operational disruption, establishing a clear, regulator-compliant roadmap for the iGaming migration and leaving fit-for-purpose delivery governance and controls in place.

Perform Partners and Betsmart Consulting responded jointly, offering an operating model that combined Perform Partners’ delivery discipline with Betsmart Consulting’s regulatory expertise.

The team stepped into a delivery environment with limited pre-existing delivery structure and governance, compounded by cross-supplier dependencies and UK/UAE time zones, and operated autonomously to establish effective planning and stakeholder communication.

Our Approach

Delivery was led using a “minus plan” approach, working backwards from the firm deadline and focusing exclusively on essential scope to achieve regulatory compliance and uninterrupted live operations.

To minimise risk to the iGaming launch, the vendor change was deliberately decoupled and scheduled for post-certification, with the lottery migration delivered first.

The approach focused on rapid governance to regain control across workstreams including Lottery integration, AWS migration, and AML alignment with suppliers (Napier, Crucial Compliance, ComplyAdvantage).

We focused on the following pillars:

• Governance & Control (charters, RACI, decision logs),
• Portfolio & Pipeline Management (sequencing and lifecycle gates),
• Supplier Governance (cadence, escalation routes, integrated into the RAID),
• Transparency & Reporting (unified dashboards),
• Health Checks & Assurance (audit-readiness indicators, traceability metrics),
• Service Transition & Handover (acceptance templates and AIS tracking).
• Handover to BAU varied widely, with no standard acceptance or post implementation reviews.
• Introduced acceptance templates and closure criteria linked to delivery success.
• Introduced Acceptance into Service (AIS) as embedded activities in the core delivery lifecycle ensured transition is planned for rather than an afterthought.

Delivery was structured through 3 engagement phases, supported by an integrated governance model with defined roles spanning client liaison, governance lead, portfolio advisor and PMO coordination:

1. Discovery & Design

• Assess existing governance artefacts, processes and reporting cadence.
• Establish baseline maturity and key gaps and risks
• Co-design tailored governance model with client stakeholders.

2. Deployment

• Implement tools, templates, and performance dashboards.
• Establish a structured PMO reporting cadence and communication rhythm.
• Launch the Supplier Governance Board and introduce automated RAID tracking.

3. Enablement & Transition

• Train internal PMs and governance leads to ensure a capability uplift.
• Embed lifecycle ownership and accountability within client teams.
• Complete documentation handover and transition to BAU.

Supporting People Through Change

We supported people through change by establishing a structured cadence and clearer ways of working, then enabling adoption through training, embedded ownership, and BAU handover.

We worked closely with stakeholders across Legal, Compliance, Product, and InfoSec to maintain engagement, align decisions and sustain delivery momentum. Teams-based governance forums, documented minutes, and consistent reporting rhythms were used to improve clarity and build confidence.