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Here are some of the dossier’s key findings, some of which raise questions around Evolution’s compliance operations during the period assessed.

Within the initial pages of its lengthy August 2021 report, Spectrum Gaming explains it carried out an extensive technical, operational and compliance review of Evolution’s “business practices, public record database research and an assessment of the company’s anti-money laundering compliance procedures and processes, as they related to the allegations contained in the ‘anonymous report'”.

Tests carried out using a VPN to access banned markets found Evolution’s games had been available to players in the prohibited jurisdictions of UAE, Singapore, Hong Kong and Saudi Arabia.

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Medias24 reported the judge’s reasoning: “Internet access providers are technically the only parties able to end the manifestly unlawful disturbance resulting from access to unauthorised betting sites.”

The order was short-lived. The commercial court of appeal granted a stay on 26 January. According to Medias24’s 12 February report, it then annulled the order and rejected MDJS’ claim, ending the daily penalty. MDJS could still appeal.

The court action came as MDJS was warning of the financial impact of offshore betting. Director General Younes El Mechrafi told a parliamentary sport forum in December that illegal sports betting stakes reached about MAD3.5 billion in 2024. He put the cost to the state at some MAD700 million, split between the national sports development fund and the Treasury.

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However, that responsibility does not lie with the Central Bank. It is the role of the Secretariat of Prizes and Bets to monitor and regulate the sector. Betting companies submit detailed daily reports on bettors’ financial transactions with the sites. A specific module within Brazil’s betting management system detects recurring transfers.

“Today I met a young man who made 1,400 Pix transfers in three months, and the Central Bank didn’t detect that this was an excessive number of transfers to the same company?” Lula said.

“Are we remaining passive while society drowns in debt? Are we remaining passive while society is driven to madness – because this is an illness? People lose their minds; they contemplate suicide or abandoning their homes. So, we are going to take serious action.”