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“We have been there for a long time and we have our positioning quite cemented. [But] we need to look at ourselves and keep improving, keep embracing the Peruvian culture and the way we fit in the market by applying a localised approach.”

As seen in many markets, especially in LatAm, local Peruvian brands and their cultural knowledge are facing competition from international operators that often bring bigger scale in terms of technology and capital.

For Ramiro Atucha, founder and CEO of Atucha Strategic Advisory, whether international operators can press home their scalable advantages will depend on how seriously they take localisation.

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He argues that some lawyers and licensees believe the Commission’s presentation of cases is detached from the operational reality but feel they have little option other than to accept the “regulator’s truth” when settling.

“The Commission’s approach to reporting may well create the inaccurate impression that the industry is inherently non-compliant,” he adds. A more balanced account might place failures alongside the majority of licensees that pass assessments or lead on customer wellbeing, although Waugh considers such a shift unlikely.

The “too easy to get a licence” argument doesn’t necessarily hold up to scrutiny, to be fair. Andrew Bentley, co-founder and CEO of regulatory technology startup LiSense, is one who rejects the suggestion.