
A confidential compliance report commissioned by Evolution has identified its gaming content being accessed in several prohibited jurisdictions, including Hong Kong, Singapore, the United Arab Emirates and Saudi Arabia. This is according to the Financial Times.
The report was prepared by Spectrum Gaming Group to review allegations previously raised by private intelligence firm Black Cube. The findings have now emerged publicly through court proceedings involving Playtech and Evolution.
Spectrum Identifies Compliance Gaps
In a regulatory filing, Playtech said Black Cube had submitted the full Spectrum report as part of ongoing litigation. Playtech argued that its findings supported concerns over Evolution’s prohibited-market access and client monitoring practices.
Spectrum identified “significant” shortcomings in Evolution’s compliance controls, including a lack of proactive measures to ensure that operators using its content complied with contractual restrictions.
The report also found that Evolution generated revenue from operators offering its games in grey-market jurisdictions such as Hong Kong and Singapore.
Importantly, the findings related to downstream operators accessing Evolution content, rather than Evolution directly providing gambling services in those markets.
Report Examines Sanctioned-Market Allegations
Spectrum also reviewed claims that Evolution games were available in US-sanctioned jurisdictions, including Syria and Iran.
The consultant found no evidence supporting allegations that Evolution itself operated in those markets. However, Spectrum said it could not confirm or refute certain claims because Evolution had not provided requested gaming-session and revenue data relating to Iran, Syria and Sudan.
The report further noted that some transactions involving virtual currencies should have triggered enhanced due diligence. At the time of the review, Spectrum said Evolution had not taken remedial action to block the relevant sites or jurisdictions or enforce its contractual restrictions.
Dispute Between Playtech and Evolution Continues
The report originated from an investigation launched after a Playtech subsidiary engaged Black Cube in 2020 over concerns about Evolution’s activities in prohibited and sanctioned markets.
Evolution subsequently commissioned Spectrum to independently assess the allegations. The company had opposed public disclosure of the report, citing commercially sensitive information. However, a court filing by Black Cube made the full document available.
Evolution has described the broader investigation as an anti-competitive smear campaign and rejected the allegations as false and misleading.
The company has also pointed to investigations by regulators in New Jersey and Pennsylvania, which closed in February 2024 without corrective action. The related defamation litigation remains ongoing.



