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“Operators failing compliance checks is never a good look,” he says. Campaigners often claim that financial sanctions are priced in and that the Commission should revoke more licences, although Waugh does not believe operators view settlements merely as a cost of doing business.

Nor are regulatory breaches unique to gambling. Waugh notes that Tesco was fined more than £8 million for food hygiene failings in 2021, without parliamentarians demanding that it should be prevented from selling cornflakes.

“There are valid arguments to be made in relation to raising the barriers to licensing, but this may come at a cost of diminishing competition and entrepreneurship,” he says.

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

“Such operations, albeit not purposeful, may impugn the company’s reputation and potentially subject Evolution to heightened regulatory scrutiny and the imposition of sanctions,” the report continues.

In the dossier, Spectrum unpacks Evolution’s review and vetting processes for potential clients. At the time of the report, Evolution required clients to provide certification of the beneficial ownership of 25% or more of the company. But Spectrum says it was not using “a viable process” as some documents provided by companies could be inaccurate.

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The UK has historically maintained a high channelisation rate due to it being particuarly mature with a huge competitive offering. According to the report, up to 1,491 licensed sites provides sufficient choice for engaged players.

The report utilised various methods to estimate the size and scale of Europe’s black market, including web traffic, digital marketing, macros data and regulations in place across the 28 markets surveyed.

Helios, a specialist consultant in gambling web traffic, analysed the number of black market websites actively marketing across the 28 markets included in the report, between March and May.