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While the guide does not impose novel legal duties, it effectively tightens the operational framework that operators must observe to manage player fraud in France.

It has addressed ongoing questions faced by operators regarding when it is reasonable to close accounts, withhold or return player balances, cancel bets, or redistribute tournament prizes deemed fraudulently obtained. 

Notably, it has also provided insight into the evidentiary standards French courts expect operators to meet before taking corrective actions that could be subject to legal challenge.

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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.

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The contrast with land-based gambling is striking. Casinos in Morocco and Egypt operate within recognised frameworks and, in Morocco, attract international investment. Private online betting remains outside the legal market.

The scale of that unlicensed market is unclear. MDJS’ own estimate of about MAD3.5 billion a year is the only figure available. No comparable public estimate exists for Tunisia or Egypt.

Without a licensing route, these markets remain difficult to measure, tax or supervise. Blocking and criminalisation may disrupt operators, but they do not remove demand. Governments are left trying to suppress offshore betting rather than bring it within a regulated market.