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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.

“Japan is acting cautiously, after observing missteps from other jurisdictions. They are proceeding in the way that best suits them,” she adds.

The factor that led some operators to drop out of the licensing race could be the “uncertainty” created by regulations that “didn’t seem set in stone”, says Leckert.

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The firm goes on to confirm that Evolution had therefore received income from these unauthorised activities.

“Such operations, albeit not purposeful, may impugn the company’s reputation and potentially subject Evolution to heightened regulatory scrutiny and the imposition of sanctions,” the report continues.

In the dossier, Spectrum unpacks Evolution’s review and vetting processes for potential clients. At the time of the report, Evolution required clients to provide certification of the beneficial ownership of 25% or more of the company. But Spectrum says it was not using “a viable process” as some documents provided by companies could be inaccurate.

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The ongoing dispute between Evolution and Playtech continues to rumble on.

Playtech commissioned intelligence firm Black Cube to investigate Evolution’s activities in 2020, with the resulting dossier alleging Evolution supplied games into banned and sanctioned markets.

Evolution subsequently sued Black Cube and has sought to hold Playtech accountable in the related defamation case.