A 2022 report by Spectrum Gaming Capital, prepared to defend Evolution in its lawsuit against intelligence firm Black Cube, has been unsealed by a New Jersey court. The document confirms part of Black Cube's claims and identifies serious gaps in the supplier's compliance procedures.
Spectrum ran technical checks using VPN and found Evolution games available in the UAE, Singapore, Hong Kong and Saudi Arabia — jurisdictions where online gambling is prohibited. Access from sanctioned countries including Iran, Sudan and Syria was blocked, disproving part of Black Cube's allegations.
The report flags contractual breaches by Evolution clients BitCasino.com and Stake.com, connected via aggregators Hub88 and Babylon. These operators offered Evolution content in banned regions in violation of contract terms. Spectrum called Evolution's compliance procedures "ineffective" and noted the supplier failed to detect violations while earning revenue from unauthorised activity.
Consultants criticised the client vetting process: Evolution required beneficial owner certificates for stakes above 25% but did not use reliable document verification methods. Spectrum recommended stronger due diligence and revised processes before contract execution.
The report confirmed cryptocurrency use by end players on Evolution games via Hub88 — 1,124 instances, or 11.5% of sessions in the sample provided. Operators accepted the bets, but Evolution did not monitor their AML and KYC compliance for crypto transactions.
Evolution's case against Black Cube began in 2020 after an investigation commissioned by Playtech. Evolution calls it a "defamatory campaign"; Playtech says the Spectrum report validates Black Cube's findings.
