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Platforms were generally constructed for one person operating one account, rather than trading organisations requiring separate permissions and controls. According to Gonzalez, some teams still share a single login.
“Whether it’s a 10-person or 100-person fund, they log in through the same Google email and share the same login credentials, which makes no sense,” he said.
ParlayX is developing individual logins, delegated permissions and subaccounts for such teams. Other gaps include unified execution across exchanges, prime brokerage and common resolution standards.
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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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Even so, suspension is an unusually forceful intervention.
“In my experience, where compliance concerns can be satisfactorily addressed without suspending an operator’s licence, the Commission may allow the operator to implement remedial measures or an action plan while continuing to trade,” says Richard Williams, partner at Keystone Law, speaking before the news of the collapse of the businesses.
“The fact that suspension has been considered necessary in this case therefore indicates that the Commission presently considers the issues sufficiently significant to justify preventing the operators from continuing to offer gambling while its reviews are ongoing.”