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“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.
“If red flags become known to Evolution during this onboarding process, Evolution should either determine not to do business with the company or undertake enhanced due diligence to resolve the red flags before engaging in business with the company,” Spectrum advises.
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About Lucky Player
Japan’s gambling landscape has remained an enigma. It began as a seismic opportunity sought after by international casino giants following the enactment of its Integrated Resort Implementation Law in 2018, but as progress slowed potential bidders withdrew, and MGM Osaka emerged as the only new kid on the IR block, with a launch date of 2030.
Now, with Japan promising to open two more IR licences in 2027, ambitious bidders are craning their necks for a leg up over the competition. But Japan has telegraphed mixed messaging on the casino industry.
Depsite it having liberalised gambling in pursuit of the economic benefits that casinos can bring, its regulatory architecture and deeply ingrained social attitudes are not particuarly pro gambling.
