Fishtastic

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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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In March, courts in London and Dubai imposed a worldwide freezing order on Raja’s assets up to £1.3 billion.

The order requires Raja to disclose assets worth more than £10,000 ($13,000) and limits his personal spending to no more than £5,000 ($6,700) per week without explicit consent from MFS administrators.

The UK’s Financial Conduct Authority (FCA) subsequently launched an enforcement investigation into MFS.

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The sanctions, effective from 28 August 2026 , bar Santos from any direct or indirect trading access on Kalshi.

Earlier this year, fellow prediction market platform Polymarket also ended its paid relationship with Santos amid a Department of Justice investigation over whether he had placed a wager on his appearance at the same State of Union address. 

A federal judge sentenced Santos to 87 months in prison last April on felony wire fraud and check fraud charges. After Santos served several months in 2025, US President Donald Trump granted the former congressman clemency, resulting in his immediate release.