By Peter J. Kulick and Robert W. Stocker II
The meteoric fall of Full Tilt Poker during six short months in 2011 placed the highly respected Alderney Gambling Control Commission (AGCC) in a potentially precarious situation. The recently released independent report prepared by Peter Dean (the Dean Report), the former chairman of the British Gambling Commission, sheds considerable light on the circumstances surrounding AGCC's regulatory actions with respect to Full Tilt Poker.
The Dean Report largely vindicates the regulatory actions of the AGCC. Mr. Dean concludes that overall "AGC fulfilled its statutory obligations in relation to [Full Tilt Poker] and that its actions were appropriate, timely and fair." The Dean Report offers an exposé of the Full Tilt Poker licensing review. The Dean Report also suggests recommendations to strengthen the regulatory oversight of i-gaming businesses licensed in Alderney.
The Dean Report undertakes a chronological examination of the regulatory process, beginning with the licensing of Full Tilt Poker and its affiliated entities through AGCC's hearing that culminated in the revocation and suspension of the gaming licenses held by Full Tilt Poker and its affiliated marketing entities.
For the legal community, the Dean Report ultimately presents a case study of an i-gaming regulatory system's response to the failure of an operator, which includes identifying early warning signs of potential trouble and swift regulatory response to troubled situations. The Full Tilt Poker regulatory review offers an opportunity to assess existing regulatory systems to ensure that safeguards are in place to identify potential financial problems.