What Spectrum Gaming’s report says about Evolution’s compliance controls and prohibited-market access

Spectrum Gaming Capital’s 63-page report, released by the New Jersey Superior Court, is now part of the public record in Evolution’s defamation case against Black Cube. For high-risk PSPs, the useful bit is not the courtroom theater; it is the mechanics of how a supplier’s games were found accessible in prohibited markets and what the report says about compliance controls at the time.

1. Spectrum’s August 2021 report was prepared as part of Evolution’s defense and reviewed the supplier’s business practices, public-record database research, and anti-money laundering compliance procedures and processes, in relation to the allegations in the Black Cube report.
2. The report says Evolution did not knowingly allow games in prohibited territories, but it also flags compliance issues that resulted in its games being provided in markets where online gambling is, or has been, prohibited.
3. Using a VPN to test access, Spectrum found Evolution games were available to players in UAE, Singapore, Hong Kong and Saudi Arabia. That is the operational detail payment teams care about: access controls, geofencing, and distribution paths are only as good as the weakest point in the chain.
4. Spectrum also tested the sanctioned markets of Iran, Sudan and Syria and said it could not access Evolution’s games there, despite contrary claims made by Black Cube in its prior report.
5. The report had been kept confidential by Evolution until the court released it in full this week because, according to Evolution, it contained commercially sensitive material. Playtech has publicly said the document supports and corroborates findings from Black Cube.

The case itself dates back to 2020, when Playtech allegedly engaged Black Cube to investigate Evolution’s activities in prohibited and unlicensed markets. Since then, the dispute has become a reference point for how quickly market-access, compliance screening, and partner diligence can turn into litigation material for suppliers and their payment counterparties.