God Of Seas

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Here are some of the dossier’s key findings, some of which raise questions around Evolution’s compliance operations during the period assessed.

Within the initial pages of its lengthy August 2021 report, Spectrum Gaming explains 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, as they related to the allegations contained in the ‘anonymous report'”.

Tests carried out using a VPN to access banned markets found Evolution’s games had been available to players in the prohibited jurisdictions of UAE, Singapore, Hong Kong and Saudi Arabia.

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This summer, the Commission reached settlements of £900,000 with Betfred over safer gambling failures, £4.75 million with Evolution over weaknesses in its AML risk assessment and supply-chain oversight, and £122,835 with Stakelogic after games were found to be running faster than permitted.

Taken together, the cases provide further ammunition for the anti-gambling lobby at a time when it is already facing political pressure, tax increases and demands for tighter restrictions. Each apparently avoidable failure makes it harder for the industry to argue that existing regulation is sufficient.

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The Debtors here deployed an insolvency statute against the one creditor whose judgment they wished to defer and compromise, left every ordinary-course creditor untouched, preserved their own equity, and sought releases for the insiders who directed the conduct that produced the judgment—then asked this Court to treat that machinery as proof that their affairs are centered in Israel,” the petition continued.

“The Court should refuse the relief requested by … because it is manifestly contrary to the public policy of the United States based on the Debtors’ well-documented and pervasive bad faith conduct,” the petition said. “The Debtors are using the Israeli Action—a limited action which lacks many of the core characteristics of a collective insolvency proceeding—as a strategic tool to evade responsibility for their deceptive conduct.”

On Aug. 26, Tel Aviv District Court Judge Iris Lushi-Abudi rejected Papaya’s motion to pay down the Skillz judgment over 6.5 years with profits from its continuing operations.