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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'”.
Tests carried out using a VPN to access banned markets found Evolution’s games had been available to players in the prohibited jurisdictions of UAE, Singapore, Hong Kong and Saudi Arabia.
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Officials alleged that the individuals involved had been operating illegal betting websites and had facilitated the movement of proceeds from gambling through Türkiye’s financial system.
The Interior Ministry insisted that the crackdown on digital illegal gambling would persist as part of a broader strategy to prevent criminal proceeds being fed into the economy via banking and payment infrastructures.
Türkiye’s Law No. 7258 criminalises the operation of gambling activities without a licence. Offences are often combined with money laundering and fraud charges, amplifying legal consequences for offenders.
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Beynon describes Flutter as “the highest-quality online betting franchise globally”, with FanDuel’s leadership position providing “significant long-term value”. The problem is that the market is increasingly questioning how much future earnings growth can be generated from that position as the industry matures.
DraftKings is a different proposition. Its share price went from $43.30 on 18 September 2025, to $21.75 upon market closure last week. Beynon says it “arguably offers the greatest operational upside if it can continue converting strong customer growth into sustained profitability”. Its prediction market strategy could also become an advantage if the new market proves complementary to sportsbook betting.
MGM Resorts International’s investment case is supported by Las Vegas, regional casinos, property assets and its 50% interest in BetMGM. Its own share price has been on a different journey to its online pureplay peers, having increased by 5% in a year, to $37.81 on 18 September.
