Principal Consultant @ Governance Associates 

Alan Pedley



Gambling compliance & regulation

Alan served as Director of Technology Regulation for the Racing and Gaming Authority in the Northern Territory of Australia through the 1990s. During this time Alan developed a risk management approach to casino regulation, allowing the Authority to save costs of on-site Government Casino Inspectors at casinos 24hrs x 7 days to risk-based monitoring & audit.

As a technical expert Alan was a founding member of the National Standards for Gaming Machine Control (developing Australia & New Zealand National Standards); Alan managed Australia's only on-time, on-budget implementation of a jurisdiction-wide, centrally monitored, gaming machine industry.

He bought sports-betting regulation to new levels, over-seeing the birth of Australia's regulated, online wagering industry (the first regulated industry in the world). This was followed by regulated, online casino gaming in 1999.
Since leaving government Alan's casino, slot machine, sports-betting regulation, and remote gambling regulatory expertise has been utilised by government regulators seeking critical expertise and skills transfer and gambling operators seeking low cost compliance.

Online gambling

The world's first online gambling regulator (regulated online sports-betting circa 1995 and regulated online gaming circa 1997). Since 1999, Alan has consulted to regulators world-wide with regard to online gambling regulations, including Alderney; Antigua & Barbuda; Curacao; Denmark; Great Britain; Jamaica; Macao; Malta; Norfolk Island; Northern Territory of Australia; St Kitts & Nevis; South Africa; Trinidad & Tobago; and others.

Alan is in high demand implementing compliance programs, and compliance-as-a-service, for online regulators, operators, and vendors, undertaking projects worldwide:

Anti-money laundering & counter financing of terrorism (AML/CFT)

Since 2007 Alan has assisted jurisdictions in implementing efficient (low cost) but effective (compliant) AML/CFT programs across gambling industries. These programs have greatly assisted in jurisdictional compliance with FATF Mutual Evaluations. Alan is approved by AUSTRAC (Australia's Financial Intelligence Unit) as an external auditor for AML/CFT programs. Alan has provided training to several financial intelligence units (FIUs), assisted with AML/CFT National Risk Assessment (NRA), devised and implemented gambling regulatory models, and for casinos devised AML/CFT programs which have passed audit and scrutiny of respective FIUs.

National risk assessment & mutual evaluation preparation consultant

Alan provided expert consulting services to regulatory and supervisory authorities Caribbean Financial Action Task Force jurisdictions in preparation for 3rd and 4th round mutual evaluations. Services included AML/CFT training, risk management, and risk treatment strategies.

Mandatory regular independent review

The Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth) mandates regular independent reviews of Part A of gambling operators' AML/CTF Program. Alan undertakes these mandatory regular independent reviews for several Designated Non-Financial Businesses or Professions (DNFBPs).

AUSTRAC direction for external auditor

Alan is approved by AUSTRAC to act as an external auditor pursuant to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). Where reporting entities are instructed by AUSTRAC to appoint an external auditor then Alan is an experienced auditor for this activity, having undertaken external audit roles.

Money laundering reporting officer (MLRO) as-a-service

Through Governance Associates Alan leads a team of Certified Anti-Money Laundering Specialists (CAMS) accredited consultants with remote gambling regulatory experience. This allows the team's expertise to provide low cost Money Laundering Reporting Officer (MLRO) and gambling compliance services at a fraction of the cost of retaining such expertise on staff compliance as a service.

Casino

Integrating his AML/CFT expertise with experience gained as a Government Casino Inspector (GCI) with the NT Casino Control Division, Alan provides AML/CFT programmes and training to casino operators, casino regulators, and financial intelligence units.

AML/CFT program implementation

Alan's expertise has been utilised by several casinos and remote gambling operators to devise and implement compliant AML/CFT programs customised to specific jurisdictional and business requirements.

Responsible gambling

As a gambling regulator, Alan was principal in establishing Australia's "Draft Regulatory Model" in 1997, which evolved into the AUSModel - a world first regulatory effort to promote responsible gambling.

Since 2007 Alan has developed algorithms to support the detection of behaviour consistent with excessive gambling. These algorithms can be used in conjunction with RegTech by live-studios, slot machines, sports betting, and online casinos.

RegTech

As the regulator responsible for overseeing transaction-intensive technology-centric industries Alan has been specifying data capture and analysis systems for regulatory purposes well before it was known as RegTech.

Alan has implemented RegTech to effectively regulate online gambling industries since the mid-1990s in several jurisdictions worldwide. The systems assist regulatory oversight of online gaming, wagering, and slot machines (fairness, integrity, revenue, and responsibility); AML; and live-studio governance.

Sports-betting & sports integrity

As Director of Technology Regulation Alan devised a sports-betting monitoring system in the mid-1990s. This and subsequent systems developed for new and emerging markets have used expert systems rules devised and refined over decades to detect problem gambling, money laundering, suspicious betting, suspicious events, etc.

Information security management systems & cyber security

Alan has been an information security management systems (ISMS) advocate (implementing and auditing) throughout his career. He is British Standards Institute (BSI) ISO27001:2007 Lead Auditor trained; and ISO27001:2013: ISO27001 Certified ISMS Lead Auditor (CIS LA); and ISO27001 Certified ISMS Lead Implementer (CIS LI). When employed by an appropriately accredited company Alan was also a Payment Card Industry (PCI) Qualified Security Assessor (QSA) and Payment Application Qualified Security Assessor (PA QSA). Thus whatever your needs ISO27001 ISMS or PCI, Alan is able to implement a compliant program.

Alan also undertakes systems evaluations and mandatory annual reviews pursuant to the Northern Territory government requirements of online sports-betting businesses - Governance Associates provides this service through our NT approved Australian company AML Governance Associates.

EU General Data Protection Regulation (EU GDPR)

Alan is certified in accordance with ISO 27024 - Certified EU General Data Protection Regulation - Foundation (GDPR-F).

Data protection officer (DPO) as-a-service

Gambling companies throughout Europe must systemically analyse customer data for anti-money laundering (AML) compliance. This triggers the Article 37 requirement to appoint a Data protection officer. Like-the MLRO as-a-service above, DPO-as-a-service or data protection impact assessment (Article 35) are also offered.

Northern Territory of Australia, sports-betting

As Director of Systems Regulation with the, then named, Northern Territory Racing & Gaming Authority Alan devised the first sports-betting regulatory requirements. He regularly undertakes the AUSTRAC mandated regular independent reviews of Part A, AML/CTF Programs (see above) and NT Government mandated annual technical systems review. This dual accredited capability saves sports-betting operators time and money through reduced annual audit intrusion.

Gambling, systems, and AML/CFT standards

Technical & control systems standards

These services have been particularly useful for jurisdictions implementing gambling regulation for the first time (for example Denmark and Alderney establishing remote gambling) or when technologies change (for example Alderney cloud standards), or for non-G20 jurisdictions seeking effective but affordable regulation in existing industries (for example Jamaica, Antigua & Barbuda).

Responsible gambling programs

Alan has developed and implemented policies and procedures (including algorithms) which have been successful in reducing the incidence of excessive gambling in gaming machine and remote gambling sectors. These methods align with AML and compliance efforts above and underline the value in outsourcing compliance & governance activities.

AML/CFT standards

Alan has developed DNFBP AML/CFT minimum control systems requirements for multiple jurisdictions.

Live studios

Alan has undertaken dozens of audits, risk assessments, and control development for live studios.

Compliance officer as a service

Alan has devised remote compliance officer -as-a-service programmes which have been implemented by UK remote gaming operators. These programmes save operators substantial amount of monies.