Evolution Risked Licence Suspension Following Serious AML Failings

The Gambling Commission considered suspending Evolution’s UK licence after uncovering serious weaknesses in the supplier’s anti-money laundering controls and oversight of its distribution network.

Further details published by the regulator revealed that Evolution’s risk assessments failed to identify two third-party operators supplying its games to unlicensed websites accessible from Great Britain. The Commission ultimately decided against suspension after Evolution responded quickly and strengthened its controls.

Evolution’s AML assessment failed to reflect real-world risks

The investigation found that  Evolution had not taken appropriate steps to identify and assess the risks of its business being used for money laundering or terrorist financing.

Its AML risk assessment was described as outdated and failed to adequately consider the possibility that licensed content could be distributed through unlicensed operators.

John Pierce, director of enforcement at the Gambling Commission, said this created “a significant gap between the controls on paper and their effectiveness in practice”.

The failings included breaches of Licence Conditions 12.1.1 and 12.1.2, covering risk assessments, AML policies and compliance with customer due diligence requirements.

“The Commission’s investigation and testing uncovered failings that were serious enough for us to consider licence suspension.” – John Pierce

Games appeared on six unlicensed websites

The Commission opened its investigation after identifying Evolution games on websites that did not hold the necessary licences to serve consumers in Great Britain.

Evolution’s titles appeared across six unlicensed websites operated by two third-party businesses between December 2023 and November 2024. The regulator said the sites received large volumes of visits from UK consumers.

Evolution confirmed that the games were genuine and blocked access from Great Britain after the Commission formally raised its concerns in December 2024.

However, the investigation found that weaknesses in Evolution’s due diligence and ongoing monitoring had prevented it from identifying the unlicensed distribution sooner.

Swift response prevented licence suspension

Despite the seriousness of the breaches, the Commission chose not to suspend Evolution’s software and game-host licences.

Pierce said Evolution had responded “swiftly and comprehensively” once the issues were identified. The supplier strengthened its controls, addressed the regulator’s concerns and implemented extensive ring-fencing measures across its European operations.

Subsequent testing by the Commission did not identify any further instances of Evolution content being supplied to unlicensed operators targeting British consumers.

The regulatory settlement requires Evolution to pay £4.75 million and cover the Commission’s investigation costs. Its UK licence arrangements must also undergo an independent audit within the next 12 months.

Commission issues wider supply-chain warning

The Commission said the case should serve as a warning to other licensed suppliers about the importance of understanding where and how their products are distributed.

Suppliers must ensure that their risk assessments remain current, are regularly tested and reflect how their content is accessed in practice. This includes maintaining sufficient oversight of third parties and identifying any routes through which licensed games could reach the illegal market.

The regulator also warned that it would continue testing gambling websites to identify content from licensed suppliers appearing on illegal platforms.

Evolution CEO Martin Carlesund has maintained that the settlement will not change the company’s approach to the regulated UK market. During its latest earnings call, he said there were no planned changes to Evolution’s UK operations.