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“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.
“If red flags become known to Evolution during this onboarding process, Evolution should either determine not to do business with the company or undertake enhanced due diligence to resolve the red flags before engaging in business with the company,” Spectrum advises.
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The initiative is based around a core objective of ensuring the growth of the gambling sector in Africa runs alongside “effective consumer protection, responsible gambling practices and greater public awareness”.
Under the campaign banner #PlaySafeAfrica, each day of this week will focus on a specific aspect of safer gambling. These include responsible gambling, personal limits and the prevention of underage gambling.
The week will feature a coordinated programme of engagement between regulators and the industry, as well as public education and digital awareness activities.
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The court also explored potential liabilities for trust administrators and local representatives who facilitate illegal gambling sites.
While it did not find Curaçao-based trust firm DECC and its directors liable in this case, the ruling signalled that closer scrutiny of such intermediaries could unfold.
Nederlandse Loterij has announced plans to appeal portions of the Lalabet decision, particularly arguing that trust firms have a duty to properly vet their clients.