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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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His analogy is a poker table at which the weaker participants sustain the game. If those players disappear, the fourth-best professional at the table can suddenly become a loser because only the three strongest remain.

The US addressable market is vastly larger and customer recruitment remains strong. Marantelli says Kalshi increased its number of clients fivefold during the World Cup, while White Swan predicts that NFL prediction markets could generate between $5 billion and $7 billion of liability in a single week.

But he acknowledges the possibility that faster customer losses could eventually test the sustainability of the model.