What we learned from Spectrum Gaming’s Evolution report

A report released this week in a New Jersey court case puts fresh detail around a question that matters to everyday casino players: how reliably a game supplier’s content stays out of places it isn’t meant to be. The document, a 63-page dossier from specialist gaming advisers Spectrum Gaming Capital, flags what it calls “ineffective compliance procedures” at Evolution during the period assessed, and it confirms that Evolution games could be accessed in several prohibited jurisdictions during Spectrum’s testing.

The report is now public because it was filed as evidence in Evolution’s ongoing defamation lawsuit against intelligence firm Black Cube in the New Jersey Superior Court, a dispute dating back to 2020. Black Cube’s investigation was allegedly commissioned by Playtech and involved secretly recorded interviews and conversations with Evolution staff members and other whistleblowers. Black Cube’s report accused Evolution of knowingly providing services in prohibited and unlicensed markets; Evolution has described it as a “smear campaign” and has strongly refuted the claims as “highly inflammatory and knowingly false.” Spectrum’s review was intended to support Evolution’s defence and counter Black Cube’s allegations, and Evolution previously kept it confidential, saying it contained commercially sensitive material.

Spectrum says 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,” focusing on allegations from the “anonymous report.” A core part of its work was practical access testing: using a VPN, Spectrum found Evolution’s games had been available to players in the prohibited jurisdictions of the UAE, Singapore, Hong Kong and Saudi Arabia. But Spectrum also reports it could not access Evolution’s games via VPN in the sanctioned markets of Iran, Sudan and Syria, stating that attempts were “repeatedly denied access.” On that point, Spectrum said allegations tied to those three countries were “unsupportable and lacking credibility and proper foundation.”

Where Spectrum becomes most pointed is on how prohibited access happened at all. It found that BitCasino.com and Stake.com were knowingly offering Evolution’s games in banned markets that were explicitly prohibited in their contracts with Evolution. Spectrum’s judgment was that Evolution’s “ineffective compliance procedures” allowed this to go undetected, warning that Evolution “may be unwittingly susceptible” to third-party operators offering its games in violation of contract terms. Even if unintentional, Spectrum noted, this kind of activity could damage reputation and expose the supplier to heightened regulatory scrutiny and possible sanctions.

The dossier also digs into Evolution’s onboarding and vetting of clients. At the time, Spectrum says Evolution required clients to provide certification of beneficial ownership at the 25% threshold or more, but it criticized the process as not “viable,” because some documents provided by companies could be inaccurate. Spectrum’s recommendation was straightforward: if red flags appear during onboarding, Evolution should either avoid doing business with that company or carry out enhanced due diligence to resolve the red flags before moving forward.

Spectrum revisited several employee claims that Black Cube had leaned on, including an interview Black Cube conducted with Ezugi CEO Kfir Kugler, which Black Cube said supported the idea that Evolution knowingly supplied games in markets sanctioned by the New Jersey Division of Gaming Enforcement. Spectrum conducted follow-up interviews with employees who had “provided derogatory information” about Evolution’s practices, and it said all cooperated fully; some had “virtually little or no familiarity with the allegations,” because their roles sat outside the areas in question. Kugler told Spectrum it was never his intention to provide incriminating information, that he felt duped by Black Cube, and that he believed the person he met used a fake identity. Spectrum notes Kugler’s position that Evolution does not supply games to Iran, while also recording his remark: “I know we have players in Dubai.”

Another disputed area was crypto. Black Cube claimed Evolution accepted wagers in virtual currencies and cash; Spectrum’s finding was that end users did place wagers using cryptocurrencies, but the bets were accepted by the operator, not Evolution. After reviewing part of a 75-page PDF spreadsheet of transactions provided by Evolution, Spectrum found crypto wagers had been placed on Evolution games distributed via Hub88, and it identified up to 1,124 occurrences of virtual currencies being used, representing 11.5% of the sessions included in that spreadsheet. Spectrum also flagged a controls gap here: it said Evolution relies on clients to implement additional AML and KYC procedures for this activity and “does not review the operator’s compliance” with the requirement for enhanced due diligence.

For players, the immediate takeaway isn’t that a specific game is changing today, but that the court release provides rare, detailed evidence of how geoblocking, operator behavior, and anti-money laundering checks can fail or be disputed behind the scenes—issues that can ultimately drive regulator attention and affect which casinos and game libraries stay available over time.