Buffalo Blitz

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“In our judgment, Evolution’s ineffective compliance procesures have allowed these situations to develop and therefore need prompt reevaluation and enhancement in order to comply fully with the terms of the contracts,” the report reads.

“Evolution may be unwittingly susceptible to having its games played through third-party operators, in violation of its contracts…”

The firm goes on to confirm that Evolution had therefore received income from these unauthorised activities.

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UK operators already carry out enhanced checks on politically exposed persons (PEPs), but this case shows the limits of those safeguards, Bethan Lloyd, partner at law firm Wiggin, recently told iGB.

“PEP status does not prevent someone from gambling,” Lloyd explained. She said PEPs are entitled to bet, but not on events where inside information gives them an unfair advantage.

A low ranking MP or parliamentary aide is unlikely to meet the threshold for PEP status. She argued it would place an onerous burden on operators to verify every customer’s occupation.

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The “too easy to get a licence” argument doesn’t necessarily hold up to scrutiny, to be fair. Andrew Bentley, co-founder and CEO of regulatory technology startup LiSense, is one who rejects the suggestion.

“There are significant checks on individuals and businesses before a licence is granted,” he says. “The UK Gambling Commission has set out what it expects. If you want a licence in the UK, you need to meet those expectations.”

Bentley believes regulated operators are genuinely trying to do the right thing but says some mistakes could be mitigated through better automation and continuous monitoring. Enforcement statements also provide lessons that businesses should use to test their own exposure.