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“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.
An interview carried out by Black Cube with CEO of games developer Ezugi Kfir Kugler had allegedly confirmed that Evolution knowingly provided games in markets sanctioned by the New Jersey Division of Gaming Enforcement.
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In his original complaint, Braun also cited a study that found that nearly half of respondents were thinking of using illegal gambling services due to legal restrictions.
In recent weeks, German authorities conducted a crackdown on an alleged illegal online gambling operation suspected of facilitating wagers totalling approximately €5.86 billion over a 30-month period.
The DSWV trade body, representing licensed sports-betting operators, broadly welcomed the enforcement action as a necessary response to the illegal market’s growth and associated risks.
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A 1% selective consumption tax (ISC) on the value of every online bet has been in force since 1 July 2025, after the original policy was scrapped from proposed regulations in July 2021.
Atucha warns that regulations are often perceived as operator-friendly at the start before governments begin looking to squeeze licensed sectors, likening the process to “boiling a frog”. He has observed similar scenarios in other LatAm markets, with tax increases occurring in Brazil, Colombia and Mexico in the last couple of years.
Rossi believes the ISC in Peru is an example of a government implementing new taxes without truly understanding how the industry works, and the potential impacts on channelisation to licensed offerings.