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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.
The regulator noted that several operators received “additional points for attention”, indicating that while these applicants met minimum legal thresholds, the KSA expected continuous improvements in compliance practices.
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While there were differing views on much of the content, one area in which Dutch MPs were united was the illegal market.
The majority of parties, including those representing the ChristenUnie, PRO and SGP, all voiced their opinions that increased enforcement against black market operators should be carried out.
Members pushed the government for further action to block illegal websites, in the same way it provides power to quickly address terrorist and child pornography sites.
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The firm goes on to confirm that Evolution had therefore received income from these unauthorised activities.
“Such operations, albeit not purposeful, may impugn the company’s reputation and potentially subject Evolution to heightened regulatory scrutiny and the imposition of sanctions,” the report continues.
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.