Aayush Gupta — Risk, Controls & Compliance Leader

Transforming Risk into Resilience through Human-Centric Design

Strategic risk, controls and compliance leadership — building trust and operational excellence in complex, high-growth environments. 16+ years across gaming, payments, digital lending, consulting and audit.

Aayush Gupta - Risk, Controls and Compliance Leader
Aayush Gupta
AVP & Head – Risk, Controls & Compliance, Flutter Entertainment
  • check_circle16+ years institutionalizing ERM, Product Risk, Regulatory Compliance, AML/CFT and Internal Audit.
  • check_circleData-driven risk management for systems processing 1 Bn+ transactions a month.
  • check_circleDelivered programs across US, UK, Middle East, Africa, Europe and Asia.
  • check_circleBuilt & led multi-disciplinary risk teams of CAs, lawyers, cyber & data specialists.
  • check_circleChartered Accountant · MSc IT · ISACA Cybersecurity Audit certified.

Career Progression

A journey of driving risk excellence across leading organizations. Hover (or tap) each milestone to expand.

Aug 2023 – Present

Flutter (Junglee Games)

AVP & Head – Risk, Controls & Compliance

Jul 2022 – Jul 2023

Tata Neu

Director – Fintech Product Risk (Trust & Safety)

Jul 2021 – Jun 2022

Dhani (Indiabulls Consumer Finance)

Head of Risk

May 2019 – Jun 2021

Paytm

DGM Risk Management and CEO's Controls Office

Oct 2017 – May 2019

Centrient (Bain Capital)

AMEA Head – Risk Management

Nov 2011 – Sep 2017

EY & PwC

Consultant → Manager, Risk Advisory

public

Geographies Worked

Delivered risk, compliance and audit engagements — many as short-term, on-site assignments — across 12+ countries spanning four continents.

Indian Sub-continent
USA
United Kingdom
Middle East
Africa

Strategic Governance: Orchestrating Resilience Across Three Lines

Establishing robust, integrated governance across ERM, controls monitoring, internal audits, AML and ABC — for pre-IPO, public-listed and SEC-regulated entities.

100%
ISO 27001

Org-wide certification driven.

€550 Mn
Bain DD

Acquisition controls, zero defects.

AI
Governance Agent

Real-time compliance status.

$2.5 Bn
IPO Readiness

Paytm governance framework.

Flutter Entertainment / Junglee Games

Flutter Entertainment (Junglee Games)

  • arrow_forward_iosEstablished governance framework comprising Product Controls & Compliance monitoring, ISO 31000 aligned ERM, Regulatory Compliance monitoring, Process Governance, Financial & Data controls, AML and ABC, integrating Junglee into the Group's enterprise controls environment.
  • arrow_forward_iosLeading implementation of DPDP for product & functional streams and AI governance. Supervised the organisation-wide ISO 27001 certification.
  • arrow_forward_iosEstablished the ethics framework comprising the Code of Conduct, Anti-Bribery & Corruption Policy and Whistleblower programme; led organisation-wide & Board-level training, and served as Ombudsman and Chief Investigator for whistleblower complaints.
  • arrow_forward_iosDeveloped and deployed (with engineering team) a corporate governance AI agent which assimilates, analyses and responds with compliance status or compliance risk assessment based on organizational context.
SEC controlsERM · ISO 31000ISO 27001AI GovernanceDPDP · Data PrivacyAML & ABC
Paytm

Paytm (One97 Communications)

  • arrow_forward_iosSelected by the Founder, Board and investors as part of a three-member transformation office to institutionalise corporate governance ahead of Paytm's ~$2.5Bn IPO to design and implement enterprise governance, risk and compliance frameworks across Payments, Lending, Wealth, Insurance, Consumer Internet and Gaming businesses.
  • arrow_forward_iosInstitutionalised and led Enterprise Risk Management, Risk based Internal Audit planning, Legal & Regulatory Compliance monitoring, Whistleblower, Anti-Bribery & Corruption, ISO 22301-aligned BCDR, and bi-annual forensic spend reviews.
Pre-IPO GovernanceRBI PA/PPINPCIABC & WhistleblowerBCDR
Tata Neu

Tata Neu (Tata Digital)

  • arrow_forward_iosHands on experience institutionalizing compliance frameworks for RBI's PA, PPI, Digital Lending Guidelines and NPCI compliance requirements; led GRC tracks for Tata Payments' PA and PPI applications to RBI, securing regulatory approvals.
RBI PA/PPIDigital Lending GuidelinesNPCIRegulatory Approvals
Bain Capital / Centrient Pharmaceuticals

Bain Capital Portfolio — Centrient Pharmaceuticals

  • arrow_forward_iosAMEA Risk Management anchor for Bain Capital's €550 Mn acquisition of Centrient. Implemented a class leading internal controls framework for commercial & financial processes while managing the transaction & transition risk during acquisition. Re-engineered the strategic risk monitoring and reporting framework, reducing gross risk exposure by 35% within 18 months.
M&A Due DiligenceInternal ControlsSanctionsISO 22301

Safeguarding Innovation at Scale: Product Risk & Compliance

Robust, scalable risk architectures and near-real-time controls that protect millions of users and billions in transactions — without compromising a frictionless experience.

Flutter/Junglee Games

Flutter Entertainment (Junglee Games)

120M+
Players Protected
₹1K Cr
Monthly Funds Managed
  • arrow_forward_iosLed a cross functional team to implement real-time monitoring of product controls for ~500M monthly transactions, covering matchmaking, gameplay anti-fraud controls, geo-blocking, KYC, deposits, and withdrawals.
  • arrow_forward_iosSetup automated assurance over ~₹1,000 Cr monthly funds management and transaction fees. Reducing effort from 7 man-days to a few hours.
  • arrow_forward_iosBuilt an AI agent to automate marketing collateral reviews against regulatory guidelines, reducing review time from 2–3 hours to minutes.
  • arrow_forward_iosLed the Safer Gaming charter for a 120M+ player base, building an integrated intervention framework that increased player protection tool adoption 15x while positively impacting revenue.
Controls AssuranceFunds MonitoringAI AgentsResponsible Gaming
Tata Neu

Tata Neu (Tata Digital)

  • arrow_forward_iosDesigned the alternate data strategy for launch of digital lending and BNPL businesses, embedding product controls to accelerate credit approvals while preventing identity theft and account takeover. (40,000+ Loans; ₹400+ Crore disbursed).
  • arrow_forward_iosSet up product & process controls for TATA Neu × HDFC co-brand credit card launch (1 Mn+ cards issued). Ensured compliance with RBI-guidelines and partner-bank requirements across customer onboarding journey and hand-off points, data-sharing controls, billing & reward-point reconciliations, redemption flows and fair-usage limits.
  • arrow_forward_iosUPI & Gift Card Fraud Prevention: Designed a first-principles based fraud management framework that delivered enterprise-grade fraud controls without a dedicated fraud platform, combining customer communications, contextual product interventions, transactional rules and dynamic watchlists.
Trust & SafetyCo-brand Credit CardUPI / Gift-card FraudFirst-principles ControlsRBI PA/PPI
Indiabulls/Dhani

Dhani (Indiabulls Consumer Finance)

10+
Data Sources Validated
2x
Conversion Rate
  • arrow_forward_iosConceptualised and institutionalised the Dhani Customer Trust Score (pre-AI era), an analytics-driven model using 10+ data sources to validate customer authenticity, doubling conversion rates with no increase in Day 90 DPD.
  • arrow_forward_iosBuilt and led the Fraud Analytics function, redesigning risk analytics to evaluate signals in conjunction with business metrics and operational insights, reducing false positives in credit risk actions by 75%.
  • arrow_forward_iosCo-developed, with the product team, an in-house sanctions screening product referencing 20+ sanctions / financial-crime lists — refreshing its inventory daily and matching new and existing customers each day, with reverse (delta) screening.
Credit RiskFraud Analytics TeamContextual ReportingDevice FingerprintingFraud Controls
Paytm

Paytm (One97 Communications)

20M+
Merchants Monitored
1B+
Monthly Transactions
100%
Precision Improvement
  • arrow_forward_iosPromoted to be the Head of Risk Strategy and Analytics for payments and consumer internet businesses spanning 20Mn+ merchants who accepted Paytm for more than 1 Billion transactions every month. Led the teams designing transaction monitoring rules and deploying these to the product with Paytm's proprietary AI powered platform to identify and mitigate ecosystem abusers
  • arrow_forward_iosRedesigned transaction monitoring rules for the merchant payments business, doubling precision (true positives) and increasing recall (detection coverage) to ~80%, without additional operational headcount.
Transaction MonitoringMachine LearningFraud Analytics

Audit Excellence: Scaling Assurance in High-Growth Environments

Comprehensive risk assessment, audit-committee leadership and Big-4-partnered internal audit delivery — across listed companies and start-ups, four continents, and a forensic lens.

15,000+
Hours Supervised

In-house IA lead & consulting manager.

16+
Countries

Indian sub-continent, US, UK, Africa.

4
Sectors

Payments, FMCG, ITeS/GCC, Tech.

$300M+
Analyzed

Forensic spend reviews.

assignmentPaytm — Annual Audit Plan & Forensic Reviews

  • arrow_forward_iosLed execution and reporting of annual internal audit plan with Big Four firms for 6 entities (15,000+ audit hours annually)

query_statsFlutter Entertainment (Junglee Games) — Risk Assessment & Audit Planning

  • arrow_forward_iosInstitutionalised the annual internal audit risk assessment and audit planning process with Flutter Group Internal Audit. Bridged the gap between auditors and business stakeholders by preparing first-time auditees and equipping audit teams with product, operational, and India-specific regulatory insights.

paymentsForensic Spend Analysis

  • arrow_forward_iosLed the bi-annual forensic spend analysis covering a spend of more than $300 Mn and subsequent investigations for any identified exceptions.

hubCentrient — Unified Enterprise Controls Framework

  • arrow_forward_iosConsolidated SOX, IFC, and Internal Audit into a unified enterprise controls framework (“Nimble”), redesigning two-thirds of controls to be automated or tested using data analytics, reducing manual effort while improving control effectiveness.

local_shippingLeading Indian FMCG Company

  • arrow_forward_iosFor India's leading FMCG company (then ~₹10,000 Cr in revenue), managed delivery of 12,000+ audit hours annually across 12 countries spanning the Indian subcontinent, Middle East, Africa, the US, and Europe. Audits covered manufacturing operations, quality assurance, material planning, supply chain, trade discounts, and other critical business processes.

businessLarge Third-Party ITeS Enterprise

  • arrow_forward_iosFor one of India's largest third-party ITeS enterprises (then ~$2.5Bn in revenue), led delivery of internal audits, controls reviews, forensic investigations, and operational risk engagements averaging over 10,000 man-hours annually. These engagements spanned manpower planning and utilisation, recruitment and background verification, delivery and quality adherence under client outsourcing contracts, and other core operating processes.

Precision Advisory: Consulting & Transformation

Bottom-line transformation for digital product companies, and six years of risk advisory and process re-engineering with EY & PwC across technology, manufacturing, ITeS and FMCG leaders worldwide.

Transformation Experience with Digital Product Companies

Paytm

Paytm (One97 Communications)

arrow_forward_iosDelivered ~4% bottom-line improvement by identifying and implementing improvements to reduce revenue leakages and optimise costs across business, operations and corporate functions.
Flutter/Junglee Games

Flutter Entertainment (Junglee Games)

arrow_forward_iosImplemented a FATF aligned AML/CFT and Sanctions monitoring program in line with SEC requirements (as part of Flutter's globally integrated approach) and balancing the implementation from an Indian regulatory ask perspective.
arrow_forward_iosResilience through the post-ban pivot: Post PROGA (the law banning core real money gaming business), I moved from defence to design, executing a clean, evidence-grade wind-down with every money game and bonus disabled, no cash-game surface left live, and several million dollars of player balances reconciled and returned with zero defects.
arrow_forward_iosWorked with the engineering team to build and productise an OSINT intelligence capability that continuously monitors the illegal offshore gambling ecosystem operating in India, fusing seven independent data streams of search demand, active websites, paid advertising and organic social, App Store / Play Store, APK inventories, and active UPI handles.
Indiabulls/Dhani

Dhani (Indiabulls Consumer Finance)

arrow_forward_iosEvaluated 10+ technology products for device fingerprinting tech and implemented a cutting edge tech product to establish device based borrower identity (supplementing the KYC'd one). Created the rules for use of fingerprinting tech which was rolled out to more than 2 Mn BNPL subscribers.
Bain Capital/Centrient

Bain Capital Portfolio — Centrient Pharmaceuticals

arrow_forward_iosImplemented an ISO 22301-aligned Business Continuity Programme, covering a manufacturing site with 7 plants and ₹600 Cr annual output — a first across the Royal DSM group's 40+ manufacturing sites. This was instrumental in mitigating the impact on manufacturing operations caused by floods (2019) and Covid-19.

Consulting Experience with EY & PwC

Risk advisory, P&L ownership and process re-engineering across Asia, Africa, the Middle East, Europe and the Americas.

water_dropPremium Mineral Water Brand

arrow_forward_iosLed an end-to-end discount rationalisation programme with the National Sales Head for India's leading premium mineral water brand, improving marginal contribution by 20% and making the business EBITDA-positive for the first time since launch.

local_shippingBeverage Company — Supply Chain

arrow_forward_iosLed a supply chain optimisation programme with the Head of Supply Chain of a beverages company, redesigning the transportation model for its highest-selling product and reducing logistics costs by 50%.

account_balanceBFSI Operational Risk Management

arrow_forward_iosConceptualised and commercialised an Operational Risk Management service by adapting BFSI risk management principles for non-financial industries, enabling clients across technology, healthcare, and consumer goods to identify operational pain points, monitor KPIs, and improve service delivery across Finance, Customer Service, and IT functions.

publicGlobal Beverages Leader

arrow_forward_iosLed a process re-engineering programme for the India operations of a global beverages leader to optimise and automate field sales workforce management, underpinned by benchmarking, market assessment, and operational diagnostics.

corporate_fareEvent Risk Management

arrow_forward_iosLed the Event Risk Management practice for North India with full P&L responsibility, providing independent assurance over the integrity and effectiveness of jury-based award programs and quiz shows. Grew the practice fourfold in 18 months.

credit_cardGlobal Credit Card Issuer

arrow_forward_iosLed multiple financial, operational, and compliance audits for one of the world's largest credit card issuers, delivering engagements with stakeholder teams across APAC, Europe, and the US.

group_addTalent & Capability Build-out

arrow_forward_iosLed the end-to-end hiring program, backfilling ~30% of the team's strength (30 hires) in two months by managing the recruitment lifecycle for 400+ candidates.

contractContract Management Solution: Launch & Delivery Lead

arrow_forward_iosPart of the launch team for a Contract Management service offering for the technology sector, leading go-to-market initiatives through client proposals, solution collateral and delivery capability building for a 25+ member team. Established the contract management function for one of India's largest ITeS companies, leading a 10+ member team to digitise and analyse 200+ client contracts, creating a structured obligations framework for reporting, benchmarking and governance.

account_balanceLarge Private-Sector Bank

arrow_forward_iosFraud risk analysis for one of India's largest private-sector banks' receivable-management process — assessing operational and system controls at the outsourced contact centre.

AML & Financial Crime — built for scrutiny, across regimes

Designed and led end-to-end AML/CFT and sanctions programmes aligned with a US- and UK-listed group's global FATF standards and India's PMLA requirements, spanning customer, vendor and employee screening, transaction monitoring, and STR governance for a 120M+ user base.

120 Mn+
Subjects Screened

Players, vendors & employees.

3
Regulatory Regimes

India · US-listed · UK / FATF.

Flutter/Junglee Games

Flutter Entertainment (Junglee Games)

  • arrow_forward_iosStood up a full AML/CFT program for a 120 Mn+ player base, extending due diligence to vendor and employee screening — integrated into Flutter's globally-integrated, SEC-aligned and FATF-based framework as part of a US- and UK-listed group.
  • arrow_forward_iosImplemented the sanctions / watchlist screening tool and re-engineered platform-abuse rules to also capture AML typologies — structuring, layering, collusion and mule behaviour.
  • arrow_forward_iosImplemented a FATF aligned AML/ CFT and Sanctions monitoring program in line with SEC requirements (as part of Flutter's globally integrated approach) and balancing the implementation from an Indian regulatory ask perspective.
FATF-alignedSEC / LSE-listed groupOFAC · UN · EU · UKPEP & Adverse MediaVendor & Employee Screening
Tata Neu

Tata Neu (Tata Digital)

  • arrow_forward_iosArchitected a unified, enterprise-wide screening strategy across payments, insurance and broking — common input data rails and a single screening engine deployed once for the whole group.
  • arrow_forward_iosBuilt the framework and policies to comply with the requirements stipulated by the RBI and FIU-IND viz. reporting-entity obligations, KYC and suspicious-transaction reporting.
RBIFIU-INDEnterprise ScreeningPayments · Insurance · Broking
Indiabulls/Dhani

Dhani (Indiabulls Consumer Finance)

  • arrow_forward_iosAssessed PMLA applicability for a hybrid PPI-issuer-plus-lender business model and stood up the full AML program end-to-end, working in tandem with operations, business and legal.
  • arrow_forward_iosCo-developed, with the product team, an in-house sanctions screening product referencing 20+ sanctions / financial-crime lists — refreshing its inventory daily and matching new and existing customers each day, with reverse (delta) screening.
PMLAPPI + LendingIn-house Screening Product20+ ListsReverse / Perpetual Screening

Ready to navigate your regulatory landscape?

Whether it's standing up a risk function, getting IPO-ready, scaling controls assurance, or rethinking product risk — let's talk about how structured risk frameworks can drive operational excellence.

Chartered Accountant (2010) MSc IT BCA ISACA — Cybersecurity Audit New Delhi, India