A confidential review commissioned by Evolution in 2021 found that the company was receiving revenue connected to gambling activity in jurisdictions where online casinos were prohibited. The assessment also identified weaknesses in Evolution’s oversight of whether its customers complied with contractual restrictions.
The review was prepared by Spectrum Gaming Group and has now emerged through litigation in New Jersey. Its disclosure adds a new element to the long-running dispute over allegations that Evolution’s casino games were reaching prohibited markets.
What Evolution’s review found
The Spectrum assessment identified Evolution games being accessed from Hong Kong, Singapore, the United Arab Emirates and Saudi Arabia, where online casino gambling was prohibited. It also concluded that Evolution financially benefited from activity connected to those markets.
The review did not substantiate more serious allegations involving US-sanctioned jurisdictions such as Iran and Syria.
Evolution does not accept wagers directly. It supplies casino content to operators, which manage player accounts, payments and access to games themselves.
However, the internal assessment identified inadequate oversight of whether Evolution’s customers were complying with contractual restrictions on where its content could be offered.
Weak controls over customers
Spectrum found shortcomings in Evolution’s monitoring of contractual restrictions. It also identified issues involving virtual-currency wagers where sufficient due diligence had not been conducted.
In other words, Evolution had contractual rules governing how its content could be distributed, but its own review found that the mechanisms for monitoring compliance were insufficient in 2021.
That issue is particularly important for a supplier whose games are integrated across hundreds of online casinos. The same product can be offered by an operator in a market where gambling is legal while becoming accessible to users in another jurisdiction where online casinos are prohibited.
The Black Cube investigation
The internal review followed an investigation into Evolution conducted by private intelligence firm Black Cube.
The company used operatives working under fabricated identities and secretly recorded company personnel. Court proceedings later established that rival gambling technology group Playtech had commissioned the investigation.
Black Cube’s findings were provided to New Jersey regulators in 2021. Evolution’s share price subsequently fell sharply as the allegations became public and regulatory scrutiny increased.
Evolution argued that the investigation was defamatory and designed to damage its reputation. In 2025, the company publicly identified Playtech as Black Cube’s client, while Playtech defended the investigation as legitimate.
New Jersey investigation ended without action
In February 2024, the New Jersey Division of Gaming Enforcement closed its investigation into Evolution without further action.
The regulator found no evidence that Evolution had sanctioned, promoted or permitted its content to be offered by operators in jurisdictions New Jersey considered prohibited. It also found no evidence that Evolution had materially benefited from the activity.
The newly disclosed Spectrum assessment adds another layer to that record.
The findings are not necessarily contradictory, as the two investigations had different mandates and addressed different questions. Spectrum also did not substantiate some of the most serious allegations involving sanctioned jurisdictions.
Why the document remained confidential
The Spectrum assessment may have remained private without the New Jersey litigation. Evolution sought to prevent its disclosure, arguing that it contained proprietary information.
Black Cube argued that the document was relevant to its defence against Evolution’s defamation claims. The court proceedings ultimately brought the assessment into the public record.
Its significance lies partly in who commissioned it. The review was ordered by Evolution itself rather than by its competitors or regulators.
The compliance issue goes beyond 2021
Evolution remains one of the world’s largest online casino technology suppliers, working with hundreds of operators across markets with different regulatory regimes.
Regulatory expectations for suppliers have also increased. Authorities are increasingly demanding that suppliers understand not only who their direct customers are, but where their content ultimately becomes available.
In late 2024, UK authorities opened a review of Evolution’s licence after its games were found on websites operating in Britain without the required licence. Evolution subsequently blocked access through the identified websites.
The newly disclosed Spectrum assessment adds an earlier chapter to that compliance history. In 2021, Evolution’s own advisers had identified weaknesses in customer oversight and concluded that the company was receiving money connected to gambling activity in markets where online casinos were prohibited.
Evolution declined to comment on the newly disclosed findings.
Source: Financial Times
