Risk assessment can be carried without any action, if player is classified as low risk player and then these amounts could be automatically trigger SOW request (based on casino rep post earlier in this topic) which don't really make sense or i'm just stupid, if you categorize somebody to be low risk player from RG and AML point of view, there is no change in deposits, gaming or other patterns (deposit methods, amounts, game played, stake used and many others...) and then with exact same pattern you trigger XX€ amount in 5 years (which suggest you are low roller with nothing suspicious on your account), you still are now demanded to fill up SOW and possible with some payslips, bank statements etc....
I'm pretty sure that this is not what UKGC/MGA are looking from. Some operators just take easy way out to make sure not get fined after reading these horror stories from UKGC site, but as many of us have been reading these, cases have been quite no brainers to pick up, yes, if somebody loose £10k in month, that is quite much above for what average person could/should spend on gambling and then there is clear ground to request SOW and documentation as proof do you have that money and where it's coming for, but especially this OP:s case don't make sense simple person as me, even casinos rep replied to it with reply what for quite sure is not correct (somebody could ask from UKGC is it mandatory practice that when somebody hit 2000€ lifetime deposits+withdrawals, SOW need to be done or you break regulations, i can make little bet that answer is no, if that have happen within few years without any reason to raise players risk level).
Operators really should put bit more pressure to UKGC (and now MGA getting there too bit behind) and send them some example cases like they post in their sites where casinos are fined. This would be one example and i believe that they would find many other things what could be questioned from authorities "What if player have done X, Z, Y within C time period, do we by your regulation request SOW?". Now these are just made how operators think is correct but hard to believe that license providing authorities wouldn't give you answer if you send them some particular study case and few of them, different scenarios.