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Spectrum’s report was subsequently commissioned by Evolution to refute Black Cube’s accusations. In its latest release on Wednesday, Playtech said Evolution had “publicly characterised the Spectrum Report as exonerating it”.

But Playtech has claimed that the Spectrum report, which is now publicly available, was unable “to confirm or refute” some of Black Cube’s claims, “as Evolution failed to provide Spectrum with significant information it had requested”.

Evolution declined to provide a comment on the update.

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The KSA said that applicants were previously required to detail corrective actions taken to address previous breaches and outline measures to prevent future violations.

All submissions must also now include an exit plan – a new obligation that applies across the board. This requirement, intended to ensure orderly market withdrawal, marked a move toward embedding long-term risk management into the licensing process.

It requires operators to describe in detail how they will responsibly wind down their operations should their licence not be renewed or be revoked. Or if they decide to leave the market midway through the five years between renewals.

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Here are some of the dossier’s key findings, some of which raise questions around Evolution’s compliance operations during the period assessed.

Within the initial pages of its lengthy August 2021 report, Spectrum Gaming explains it carried out an extensive technical, operational and compliance review of Evolution’s “business practices, public record database research and an assessment of the company’s anti-money laundering compliance procedures and processes, as they related to the allegations contained in the ‘anonymous report'”.

Tests carried out using a VPN to access banned markets found Evolution’s games had been available to players in the prohibited jurisdictions of UAE, Singapore, Hong Kong and Saudi Arabia.