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Is the monopoly safe, is it set in the law that it will operate forevermore? No, it’s under constant evaluation, Petra explains: “The Dutch state, represented by the Ministry of Finance, is our shareholder and they evaluate every seven years, not only us as Holland Casino, but all state-owned companies.”

One of the operator’s most significant challenges is the increase in gambling tax enforced over recent years. Petra has been particularly vocal about this and the company’s profitability has taken a reasonable hit, since the first tax increase to 34.2% of GGR came into effect on 1 January 2025.

Holland Casino now pays 37.8% of GGR to the state, as per the additional increase in 2026, but with labour tax on top the business pays around 52% before they can look at their base running costs. It is not a small burden by any stretch of the imagination, so it is heartening to see the business doing well despite the tightening tax burden.

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Lula said he intends to discuss the matter with his team and analyse potential measures to consider the social impact of online betting.

What the president does not acknowledge is that the government relies on revenue from the sector. In just the first seven months of 2026, BRL8.747 billion generated by sports betting has already flowed into public coffers. The Federal Revenue Service estimates the total could reach BRL16 billion by the end of the year. In 2025, nearly BRL9 billion was collected from sportsbooks.

The burning question is where such funds will come from if Lula shuts down the betting industry. Yet, no one points out to him that players will simply migrate to the illegal market. Betting will continue to exist, but without formal tax revenue, oversight or player protections.

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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.