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In July the Commission said its investigation had discovered the supplier had failed to maintain adequate anti-money laundering and customer due diligence controls in the UK.
It considered suspending Evolution’s licence, but the supplier acted swiftly, carrying out ring-fencing controls across Europe to prevent its games from being used in grey markets.
Evolution’s case against Black Cube continues. It even sought to add Playtech as a defendant in April.
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Many participants emphasised the need for clearer, timely and personalised information throughout every stage of their betting experience. This would include the presence of unobtrusive and empathetic staff at land-based venues.
The study highlighted significant gaps between operator disclosures and genuine player comprehension.
The Commission’s investigation into what constitutes “informed choice” in gambling involved a multi-method approach.
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In the dossier, Spectrum unpacks Evolution’s review and vetting processes for potential clients. At the time of the report, Evolution required clients to provide certification of the beneficial ownership of 25% or more of the company. But Spectrum says it was not using “a viable process” as some documents provided by companies could be inaccurate.
“If red flags become known to Evolution during this onboarding process, Evolution should either determine not to do business with the company or undertake enhanced due diligence to resolve the red flags before engaging in business with the company,” Spectrum advises.
Within its investigation Black Cube named a number of Evolution employees which it had interviewed and reported to have provided information on the company that supported the intelligence firm’s claims.
