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“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.
“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.
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The charter also made a series of other recommendations. It suggested that companies should designate a senior member of staff responsible for governance of the technology. It additionally recommended an AI oversight or ethics committee.
The framework also urged companies to implement rollback mechanisms and “kill-switch” controls for higher-impact systems.
For AI-powered customer support and chat, operators are encouraged to set clear parameters for when conversations should be moved to a human member of staff. These include repeated low-confidence responses, unresolved queries, indications of distress, or a customer simply asking to speak to a human.
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What the president didn’t address is the tax revenue from betting.
In 2025, Brazil collected almost BRL10 billion ($1.97 billion) in tax revenue from the licensed sector. In the first seven months of this year alone, BRL8.7 billion generated by the activity was delivered to public coffers. The Federal Revenue Service itself estimates that the sector should reach BRL16 billion in revenue during 2026.
Besides revenue collection, another concern is legal and economic. Companies have paid over BRL2.5 billion for licences since the sector’s regulation. Certainly, the end of the activity would lead to litigation to recover the amounts paid and compensation for investments made. Furthermore, the revenue from betting is already included in the Annual Budget Law and the Budget Guidelines Law, which define the priorities for federal government spending.