7 And Crystals

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Notably, the Spectrum report does acknowledge that Evolution did not knowingly allow games in prohibited territories, however, it has also flagged a number of compliance issues, which resulted in its games being provided in markets where online gambling is, or has been, prohibited.

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'”.

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Examples included phrases like “online casino zonder Cruks” (online casino without CRUKS, the Dutch self-exclusion registry for problem gamblers) and “beste online casino buitenland” (best online casino abroad).

KVA expressed concern over the potential manipulation of Google’s autocomplete function by unauthorised operators and websites primarily set up to redirect Dutch consumers to illegal gambling offers.

While acknowledging Google’s cooperation in removing paid advertisements promoting illegal casinos, the KVA emphasised the need for the company to take more comprehensive measures addressing organic search results.

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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.