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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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One exception, he notes, could be the Seminole Tribe of Florida and their proposed Hard Rock Resort Casino in Tomakomai, Hokkaido.
“They are currently aggressively growing the Hard Rock Casino brand, with developments under way in Las Vegas, New York City, Greece, Puerto Rico and Jamaica. They will put forth an attractive development proposal, and it appears that they now have the support of local government,” Klebanow notes.
As highlighted by Klebanow, Japan’s fragmented approach to gambling regulation may impact the development of Japan’s IR gambling industry, and Suzanne Perilloux Leckert, co-founding partner of Convergence Strategy Group somewhat agrees.