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Notably, Spectrum said within its report that it did not believe Evolution had engaged in any illegal practices. It also refuted allegations concerning cash payments and the use of Evolution’s games in sanctioned countries.

However, Playtech suggested that Evolution had failed to provide data that would have let Spectrum determine whether gaming sessions had occurred in Iran, Syria and Sudan. 

It also said Spectrum was able to “specifically corroborate” Black Cube’s claims that Evolution’s games were accessible and generating revenue in several “prohibited locations”. These included Hong Kong, Singapore, the United Arab Emirates and Saudi Arabia.

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He argues that some lawyers and licensees believe the Commission’s presentation of cases is detached from the operational reality but feel they have little option other than to accept the “regulator’s truth” when settling.

“The Commission’s approach to reporting may well create the inaccurate impression that the industry is inherently non-compliant,” he adds. A more balanced account might place failures alongside the majority of licensees that pass assessments or lead on customer wellbeing, although Waugh considers such a shift unlikely.

The “too easy to get a licence” argument doesn’t necessarily hold up to scrutiny, to be fair. Andrew Bentley, co-founder and CEO of regulatory technology startup LiSense, is one who rejects the suggestion.

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As well as a statewide exclusion register, the package also set out to reduce the number of poker machines from the current figure of 87,000 across 2,100 clubs and hotels. 

The government said it aims to achieve this by increasing the forfeiture rate when gaming machine entitlements are traded from one in three to one in two. 

The NSW government initiated its first formal review of ClubGRANTS in over a decade after taking office in 2023. Although the final report was submitted in January 2025, it has yet to be released publicly.