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Notably, the Spectrum report does acknowledge that Evolution did not knowingly allow games in prohibited territories, however, it has also flagged a number of compliance issues, which resulted in its games being provided in markets where online gambling is, or has been, prohibited.

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'”.

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“Investors should view our actions through a straightforward lens: We are protecting the value of significant investments we’re making in Chicago while faithfully executing our contractual obligations,” Kim concluded. “And let me say this again – we remain fully committed to Chicago.”

Kim’s comments Monday were less detailed than others made before the Chicago City Council’s License Committee last week.

At that venue, the company’s president and interim chief financial officer, George Papanier, told officials that Bally’s will “deliver the event centre, 100 rooms of the hotel and the required food and beverage components” in early 2027, per the Chicago Sun-Times. That said, the company is reevaluating about 12% of the project’s other planned amenities in response to potential cannibalisation from video gaming terminals. The hotel plan calls for an eventual total of 500 rooms.

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The DSWV said the findings should prompt a thorough reassessment of official black market size estimates in Germany.

The DOCV, another trade body representing licensed online casino operators in Germany, also expressed support for the prosecutorial efforts. However, it emphasised that the raid exposed regulatory gaps which had allowed organised crime to flourish.

Kevin O’Neal, a DOCV board member, argued the scale of the investigation calls the GGL’s broader black market estimates into question. He cited the regulator’s 2025 activity report, which put the 2024 share at 23% (€547 million in gross gaming revenue), against Nielsen data suggesting a share of around 56%.