The Spectrum Report on Evolution Is Public and Both Sides Claim It

Evolution commissioned it in 2022 to answer Black Cube, has called it exonerating, and spent months resisting its disclosure. Now that it is out, it clears Evolution of illegal practice and of operating in sanctioned countries, and separately finds significant compliance failings and games reachable from four prohibited markets. Playtech has moved first on the reading.

• The Spectrum Gaming Group report, commissioned by Evolution in response to the Black Cube investigation Playtech paid for in 2021, has been made public through the ongoing litigation
• Spectrum said it did not believe Evolution had engaged in illegal practices, and specifically refuted the allegations that it accepted cash payments or made games available in sanctioned countries
• It found Evolution games accessible in several markets where online gaming is prohibited, including Hong Kong, Singapore, the United Arab Emirates and Saudi Arabia
• It described the compliance issues as "significant", saying Evolution "does not take any proactive steps" to ensure operators using its products meet their contractual obligations
• Spectrum could not confirm or refute some allegations because Evolution did not supply requested data on gaming sessions and revenues in Iran, Syria and Sudan

A Document Written in 2022, Argued Over Ever Since

The report at the centre of the four-year dispute between Evolution and Playtech is finally in the open. Evolution commissioned Spectrum Gaming Group to examine the allegations raised by Black Cube, the investigations firm Playtech hired in 2021 to look at Evolution's operations in prohibited markets. The report dates from August 2022, and its findings describe Evolution's practices at that time rather than its current compliance procedures.

Its publication comes through the defamation litigation between the two suppliers, and after months in which Evolution opposed disclosure on the grounds that the document could reveal sensitive proprietary financial information.

On the most serious allegations, Spectrum sided with Evolution. It said it did not believe the company had engaged in illegal practices. It specifically refuted the claims that Evolution accepted cash payments or made its games available in sanctioned countries, and found no evidence that it had operated in United States-sanctioned markets including Iran and Syria.

On compliance, the findings run the other way. Spectrum found Evolution's games were accessible in several markets where online gaming is prohibited, naming Hong Kong, Singapore, the United Arab Emirates and Saudi Arabia. It described the compliance issues it identified as "significant", and found that Evolution "does not take any proactive steps" to ensure that customer-facing operators using its products comply with their contractual obligations. It also found that Evolution received revenue from operators offering its games in grey markets, and accepted wagers in virtual currency that should have triggered enhanced due diligence. Spectrum said Evolution had neither taken remedial action to block the sites and jurisdictions identified nor enforced its contracts with the customers concerned.

A third category matters as much as either. Spectrum was unable to confirm or refute certain allegations because Evolution did not provide information it had requested, including data on gaming sessions and revenues in Iran, Syria and Sudan.

Playtech moved quickly to frame the document. It said the findings support the concerns Black Cube raised, pointing to the distribution of Evolution games in prohibited markets and to Evolution's monitoring of its operators, and highlighting Spectrum's finding that Evolution knew which countries its games were being accessed from while taking no proactive steps to enforce its contracts.

"It is evident that Evolution's concern around the release of the Spectrum Report was not related to sensitive proprietary financial information as Evolution argued, but instead, the corroboration of its 'significant' compliance issues, which according to the Spectrum Report, are 'problematic' and 'place Evolution in a precarious situation with law enforcement officials'," Playtech said. It added that it "stands by its decision to commission the original Black Cube investigation" and remains "very confident that the court proceedings will confirm the credibility and legitimacy thereof".

Evolution has previously cited the same report as evidence that Black Cube's allegations lacked merit. A separate investigation by the New Jersey Division of Gaming Enforcement examined the allegations and resulted in no action against the company. Chief executive Martin Carlesund said recently that Evolution has "systematically been progressing and winning in court, that's taken four years", and expects the dispute to run for many more.

Both Readings Are Honest, Which Is Why the Document Was Worth Fighting Over

Evolution's position, that Spectrum found no illegal practice, no cash payments and no sanctioned-market operation, is accurate. Playtech's position, that Spectrum corroborated the substance of what Black Cube alleged about prohibited-market access and monitoring, is also accurate. A report can clear a company of criminality and still document a compliance function that does not do the thing it exists to do, and this one does both. The four-year argument has been about which half is the headline, and now that both halves are public, that argument moves from press statements to a courtroom and to regulators who can read it themselves.

"Does Not Take Any Proactive Steps" Is the Line That Will Follow Evolution Around

Strip out the sanctions questions and the grey-market revenue, and one finding is uncomfortable in a way the others are not. A B2B supplier's contractual restrictions on where its games may be offered are the whole of its regulatory defence: it does not hold the player relationship, so its exposure is entirely a function of who it lets distribute and whether it checks. A finding that the company knew which jurisdictions its games were reachable from and took no proactive steps to enforce its own contracts describes a control that existed on paper. That is a 2022 finding and Evolution's procedures may well have changed, but the burden of showing that has now shifted to Evolution, which is reported to have narrowly avoided a British suspension in recent months after the Gambling Commission found it had supplied six unlicensed sites reachable by UK players.

The Refused Data Is the Part a Regulator Will Ask About First

Spectrum could not complete parts of its review because the company that commissioned it did not hand over session and revenue data for Iran, Syria and Sudan. Whatever the reason, that is the single most awkward fact in the report, because it is the one that cannot be answered by pointing at a finding. Evolution can say Spectrum found no evidence of sanctioned-market operation; Playtech can say Spectrum was prevented from looking. Neither side can settle it, and the only parties who can compel the data are the regulators now able to read the report in full.

A Compliance Fight Between Two Suppliers Is Also a Market Fight

It is worth stating plainly that Playtech is Evolution's competitor, that it paid for the original investigation, and that it is publicising a report about a rival at a moment when Evolution is fielding an unsolicited takeover approach. None of that makes the findings wrong, and Playtech is entitled to say a court should read the whole document. But readers weighing the significance should hold both things at once: the compliance findings are real, and so is the commercial interest in amplifying them.

The report has been used as a shield for four years. It turns out to work as one, and also as a fairly detailed map of where a supplier's controls were not working.