Evolution Malta Holding Limited Public Statement
Our public statements make reference to breaches of the Licence Conditions and Codes of Practice (LCCP) requirements which were in effect at the time of the breach. In some cases, the requirements have since been updated.
Operators are expected to consider the issues outlined below and review their own practices to identify and implement improvements in respect of the management of customers’ accounts.
Introduction
Licensed gambling operators have a legal duty to ensure their gambling facilities are provided in compliance with the Gambling Act 2005 (opens in new tab)(the Act), the conditions of their licence and in accordance with the licensing objectives, which are to:
- prevent gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime
- ensure that gambling is conducted in a fair, safe and open way
- protect children and other vulnerable people from being harmed or exploited by gambling.
Operators are expected to consider the issues outlined below and review their own practices to identify and implement improvements in respect of the management of customers’ accounts.
Evolution Malta Holding Limited Executive Summary
A licence review under section 116 of the Act was commenced following concerns that 5 of Evolution’s genuine games had been found on 6 websites, operated by 2 operators (the “Websites”) who were unlicensed by the Gambling Commission, yet accessible at scale to consumers in Great Britain (GB).
The Commission has information which suggests between December 2023 and November 2024, there were large volumes of visits to the Websites by UK consumers. In August 2024 the Commission identified the presence of what appeared to be Evolution games on the Websites. The Commission notified Evolution in December 2024, who confirmed they were genuine Evolution Games. This led to Evolution immediately and permanently geo-blocking those games to GB consumers on the unlicensed Websites in addition to other websites where their games were found.
The review found failings in Evolution’s controls, specifically:
- paragraphs 1, 2 and 3 of licence condition 12.1.1 requiring compliance with the prevention of Money Laundering (ML) and Terrorist Financing (TF)
- licence condition 12.1.2 requiring operators based in foreign jurisdictions to comply with the ML, TF and Transfer of Funds (Information of the Payer) Regulations 2017.
In line with our Statement of Principles for Licensing and regulation, Evolution will make a total payment in lieu of a financial penalty of £4,750,000. Details of this are set out under the heading Regulatory Settlement.
Evolution Malta Holding Limited Findings
A Commission regulatory review found:
Breach of Licence Condition 12.1.1, paragraphs 1, 2 and 3
Licence Condition 12.1.1 paragraph 1 requires:
“Licensees must conduct an assessment of the risks of their business being used for money laundering and terrorist financing. Such risk assessment must be appropriate and must be reviewed as necessary in the light of any changes of circumstances, including the introduction of new products or technology, new methods of payment by customers, changes in the customer demographic or any other material changes, and in any event reviewed at least annually.”
We found that Evolution’s risk assessment was not appropriate between April 2024 and January 2025.
The Commission found that Evolution’s 2024 risk assessment did not meet the Commission's minimum requirements particularly with regard to assessing third party risk. This then led, the Commission believes, to it not being appropriate for Evolution’s business and was insufficient to highlight that two of Evolution's customers were supplying their games to the GB market without holding a Commission licence.
Licence Condition 12.1.1 paragraph 2 requires:
“Following completion of and having regard to the risk assessment, and any review of the assessment, licensees must ensure they have appropriate policies, procedures and controls to prevent money laundering and terrorist financing.”
We found that, between April 2024 and January 2025 Evolution failed to ensure it had appropriate policies, procedures and controls to prevent money laundering and terrorist financing.
The Commission found that Evolution’s Anti-Money Laundering (AML) policies, procedures and controls were lacking in detail in relation to due diligence measures and ongoing monitoring for sub-licensees, including enhanced measures for high-risk. This contributed to the failure to have adequate policies, procedures and controls in place to monitor and identify supply to unlicensed websites accessible by GB consumers and it was unclear from these what risk-based checks were conducted.
Licence Condition 12.1.1 paragraph 3 requires:
“Following completion of and having regard to the risk assessment, and any review of the assessment, licensees must ensure they have appropriate policies, procedures and controls to prevent money laundering and terrorist financing.”
We found that, between April 2024 and January 2025 Evolution’s its policies, procedures and controls to prevent money laundering and terrorist financing were not effective in ensuring its games were only available in the GB market via Commission-licensed operators.
Licence Condition 12.1.2 requires:
“Licensees must comply with Parts 2 and 3 of the Money Laundering Regulations 2007 (UK Statutory Instrument No. 2157 of 2007) as amended by the Money Laundering (Amendment) Regulations 2007 (UK Statutory Instrument No. 3299 of 2007), or the equivalent requirements of any UK Statutory Instrument by which those regulations are amended or superseded insofar as they relate to casinos (the MLR) whether or not the MLR otherwise apply to their business.”
We found that Evolution’s policies and processes were not fully compliant and that there was a breach of licence condition 12.1.2 between April 2024 and January 2025.
We consider Evolution failed to adequately implement the measures described in the relevant regulations laid out in the 2017 Regulations for reasons including:
- not taking appropriate steps to identify and assess the risks of ML and TF resulting in its games being made available in the GB market by unlicensed operators
- not establishing and maintaining effective policies, procedure and controls needed to ensure its games were not made available in the GB market by unlicensed operators
- not sufficiently complying with regulations 18 (risk assessment by relevant persons), 19(1)(a) (policies, procedures and controls) and 28(1) (customer due diligence).
Evolution Malta Holding Limited Regulatory Settlement
This regulatory settlement consists of:
- a payment in lieu of a financial penalty of £4,750,000
- agreement to vary the operating licence to attach an additional licence condition requiring an independent audit of its relevant policies, procedures and controls within 12 months of the conclusion of the licence review
- agreement to the publication of a statement of facts in relation to this case
- payment towards the Commission’s costs of investigating the case.
In considering an appropriate resolution to this investigation, the Commission has had regard to the following aggravating and mitigating factors:
Aggravating factors
- the Commission had alerted the industry to its stance in tackling illegal gambling
- illegal market activity was detected
- the licence breaches gave rise to financial gain for the Licensee
- the serious nature of the breaches identified
- the potential impact on the licensing objective protecting vulnerable persons.
Mitigating factors
- Evolution swiftly put in place an action plan designed to remedy the failings and provided updates
- Evolution fully co-operated with the investigation and provided information by agreed deadlines
- Evolution accepted the failings at an appropriately early stage in the investigation.
Good practice
Gambling operators should take account of the failings identified in this investigation to ensure industry learning. Operators should consider the following questions and take remedial action where required:
- have you sufficiently identified the third-party risks to your business and put in place policies and procedures, particularly in relation to anti-money laundering, to mitigate the risks?
- what proactive measures are you undertaking to minimise the risk of your games appearing on the illegal market?
- are you aware of all the sites your games are appearing on? Do you have sufficient procedures in place to periodically monitor this?