Compliance Report Reveals Access to Evolution Games from Prohibited Asian Jurisdictions

An internal compliance report commissioned by B2B live casino provider Evolution AB has confirmed that the company’s games were accessible in several prohibited international jurisdictions, including key Asian territories. Prepared by independent advisory firm Spectrum Gaming Group and unsealed amid ongoing litigation in the United States, the document identifies compliance deficiencies regarding how the supplier’s content is distributed through downstream operators. The revelations provide new insight into a multi-year dispute involving international regulatory scrutiny, private intelligence investigations, and competing industry operators.

The Spectrum report was commissioned by Evolution in late 2021 to review allegations originally compiled by private intelligence firm Black Cube, which had been retained by rival gaming supplier Playtech. Spectrum concluded that it was able to specifically corroborate findings that Evolution content was accessed by players in territories where online casino wagering is strictly forbidden by law, including Hong Kong and Singapore, alongside Middle Eastern jurisdictions such as Saudi Arabia and the United Arab Emirates.

Spectrum characterized aspects of the company’s oversight structure as problematic and identified significant compliance weaknesses. According to findings cited in court disclosures, the consultancy noted that Evolution did not take sufficient proactive measures to ensure that customer-facing operators using its platforms strictly complied with contractual territorial restrictions. Spectrum observed that this absence of comprehensive secondary monitoring created operational exposure regarding local law enforcement and regulatory requirements.

The report, however, provided mixed conclusions regarding more severe allegations. While access from prohibited commercial jurisdictions was verified, Spectrum found no evidence to support claims that Evolution actively operated within jurisdictions subject to United States government sanctions, such as Iran or Syria. The consultancy noted that its assessment of those specific jurisdictions was constrained by data availability, as certain transaction logs and jurisdiction-level revenue reports were not provided during the review period.

Evolution has maintained that the findings do not demonstrate intentional wrongdoing or non-compliance with its direct licensing obligations. The supplier has consistently argued that, as a business-to-business (B2B) software provider, primary responsibility for end-user onboarding, identity verification, and jurisdictional geolocation lies with the consumer-facing (B2C) operators that license its portfolio. Following an extensive review prompted by the initial allegations, the New Jersey Division of Gaming Enforcement concluded its investigation in 2024 without taking enforcement action, stating it found no evidence that the supplier sanctioned or promoted operations in prohibited markets. Evolution has also emphasized that it has systematically strengthened its internal controls and IP-filtering tools to curb unauthorized access.

Here is the link to Playtech announcing their findings