AML, ESG and the gaming sector at SiGMA Central Europe.

At the SiGMA Europe Conference (Rome, 3–6 November 2025), the panel “Balancing the Ledger: ESG, Sustainability & the Social Balance Sheet of Gaming” brought together experts to explore how compliance, data, and integrity contribute to a more sustainable gaming industry.

• Geronimo Cardia, Founder, Studio Cardia

• Franco Bompani, Chairman, Eidos Consulting

• Daniele Raimondi, Counsel, Eversheds Sutherland Italy

• Andrea Manciulli, Chairman, Europa Atlantica

• Valentina Gilberti, Head of Customer Success and Industry Insights, SGR Compliance

In the following questions and answers, we take a closer look at SGR Compliance’s intervention, examining how AML data contribute to advancing integrity and sustainability within the gaming industry.

The discussion highlighted how sustainability and anti-money laundering (AML) are no longer separate domains, but rather two complementary dimensions of the same corporate responsibility: integrity as the foundation of social and governance sustainability.

What is an AML data provider doing on a panel about ESG and the sustainability of gaming?

At first glance, they may seem like very different worlds: on one side AML, made of controls, sanctions and suspicious transactions; on the other, ESG, which focuses on environmental, social and governance impacts.
In reality, the two are now converging.
How AML data and sustainability intersect in gaming? Integrity – the ability to prevent illicit, corrupt or opaque behaviour – is an essential component of sustainability.
And the data originally designed to combat money laundering can now also demonstrate transparency, accountability and responsibility, which are key pillars of good governance.

How can AML data be used in ESG processes?

Much of the information gathered for AML due diligence has now acquired a cross-functional value:

• Adverse media: include environmental crimes, human rights violations, and other issues relevant to the ESG domain.

• Legal & enforcement: encompass a wide range of measures and proceedings, including those aimed at identifying companies involved in prohibited activities or excluded by ethical investment funds, such as those recently addressed under the Italian Law No. 220, including the manufacture of anti-personnel mines, ammunition, or cluster munitions

These data, originally developed for AML/CFT purposes, make it possible to assess not only financial risks but also behaviours inconsistent with ESG principles.
In other words, the same information used to protect the financial system can now help evaluate a company’s social impact and ethical coherence.

Read more:
“Responsible finance and the ban on financing prohibited weapons”.

How are integrity and sustainability connected within the gaming sector?

The gaming industry has historically been among the most exposed to criminal infiltration and reputational risks.
The large volume of monetary flows, the presence of multiple operators, and the international dimension of digital platforms make this sector particularly attractive for those seeking to launder or disguise illicit funds.

In this context, operational integrity – the ability to prevent illicit, opaque or untraceable conduct – is not merely a matter of compliance but a cornerstone of sustainability.
An operator that demonstrates robust controls, traceable processes and transparent procedures:

• reduces the risk of violations and sanctions;

• strengthens the trust of stakeholders and institutions;

• consolidates its licence to operate as a competitive advantage.

Conversely, weak or inconsistent controls often lead to derisking: banks and intermediaries withdrawing from entire market segments, not because of the behaviour of individual operators, but due to a perceived systemic risk.
This is not only a regulatory issue but also a matter of economic and reputational sustainability: a sector excluded from the financial system can be neither transparent nor sustainable.

Demonstrating the strength of AML controls has therefore become an indicator of ESG responsibility, ensuring operational continuity, credibility and stakeholder trust.

Read more:
“Organized crime: adapting due diligence to evolving threats”.

Where does effective AML control originate?

An effective control framework stems from a comprehensive view of the entire value chain of operators.
In the gaming sector, this ecosystem is complex and multi-layered:

• Licence holders, acting as the regulated interface with the authorities.

• Platform and service providers, managing infrastructure and data.

• Affiliates and aggregators, promoting products and managing commercial relationships.

• Payment providers, overseeing financial transactions.

• End customers, generating the operational volumes.

Each of these actors can represent a potential entry point for risk.
For this reason, the most effective approach is not reactive but preventive and predictive, able to detect early warning signals before risks materialise.

SGR Compliance’s databases consolidate information on sanctioned entities, politically exposed persons (PEPs), criminal organisations, opaque corporate networks and indirect connections.
This intelligence enables the identification of hidden patterns and relationships between seemingly unrelated operators, a critical capability in an industry where intermediation and subcontracting are commonplace.
The result is a more timely and precise risk detection, turning data into actionable intelligence that supports a cleaner, safer and more sustainable value chain.

What does “compliance by design” mean for sustainability?

It means embedding compliance and integrity into business processes from the outset.
In gaming, this approach allows organisations to move from defensive compliance to generative compliance – one that creates value and trust.

Three key operational levels:

1. Accurate onboarding: pre-emptive verification of partners, affiliates and clients, with risk-based and well-documented criteria.

2. Continuous monitoring: daily checks on lists, adverse media and relationships between existing entities.

3. Dynamic risk assessment: regular updates to risk profiles based on real developments, avoiding static or purely formal approaches.

This model establishes a sustainable control system over time, where governance is not a mere regulatory obligation but an integral part of the ESG strategy.
The trust generated by traceable, verifiable and consistent processes represents the true ESG capital of the gaming industry – an intangible asset that drives stability, reputation and competitiveness.

What emerged from the discussion among the panellists?

All participants highlighted the importance of a multi-layered approach to gaming sustainability:

• Geronimo Cardia highlighted the importance of a clear and coherent regulatory framework and moderated the discussion, providing a thoughtful and valuable synthesis of the various contributions.

• Andrea Manciulli, Chairman of Europa Atlantica, offered a broad and strategic perspective shaped by his institutional background: former Head of the Italian Delegation to the NATO Parliamentary Assembly, Chairman of the Mediterranean and Middle East Special Group, and Vice-President of the Foreign Affairs Committee of the Italian Parliament. A lecturer and scholar of security and transnational organised crime, he emphasised that combating economic crime and promoting system integrity are fundamental components of collective security and geopolitical sustainability.

• Valentina Gilberti, Head of Customer Success and Industry Insights at SGR Compliance, demonstrated how AML data and screening and monitoring solutions can directly support sustainability across the gaming sector, turning risk information into intelligence that measures integrity and transparency.

• Franco Bompani, Chairman of Eidos Consulting, brought the perspective of a specialist in sustainability reporting, delving deeper into the parameters and indicators that should be carefully monitored.

• Daniele Raimondi, Counsel at Eversheds Sutherland Italy, shared his experience by focusing on the certification process and its central role in ensuring transparency and reliability in sustainability assessments.

Conclusion

The sustainability of the gaming industry cannot be built solely on environmental or social policies – it also depends on integrity, transparency and effective controls.
The same data that protect the financial system every day are now key tools to measure and demonstrate accountability.
In a sector where trust is the most valuable asset, integrity becomes the cornerstone on which the sustainability of the future is built.