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Playtech on Wednesday published a statement highlighting what it claimed were compliance failures at Evolution, written into the Spectrum report.

Within the report, Spectrum alleged “concerns around the availability of Evolution’s games in certain prohibited markets, the regulatory implications of its practices, and the lack of proactive monitoring of its customers”.

However the report confirms that Spectrum did not believe Evolution had engaged in any illegal practices. 

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Each settlement involved cooperation with Kalshi’s investigation. 

What distinguishes Santos’ penalty is the exchange’s allegation that he actively issued false or misleading statements to alter prices and profited materially, violating additional rules such as failure to cooperate and manipulative conduct. 

These breaches escalated his sanction to a permanent ban and a significantly larger fine compared to others involved.

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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.

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.