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The KSA said that applicants were previously required to detail corrective actions taken to address previous breaches and outline measures to prevent future violations.

All submissions must also now include an exit plan – a new obligation that applies across the board. This requirement, intended to ensure orderly market withdrawal, marked a move toward embedding long-term risk management into the licensing process.

It requires operators to describe in detail how they will responsibly wind down their operations should their licence not be renewed or be revoked. Or if they decide to leave the market midway through the five years between renewals.

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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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Its share price decline began after reaching an all-time high in September 2021. Over the course of five years it has slipped 73% to 530p.

It has been a challenging few years for Entain, having cycled through four CEOs in short succession. In November 2023 Entain agreed to pay a financial penalty totalling £585 million, plus a £20 million charitable donation and £10 million in Crown Prosecution Service (CPS) and HMRC costs. This related to a bribery case initiated by the CPS into the company’s historic operations in Turkey.

Troubles continued as it faced declining growth within its digital business. Reports of failed integrations amid a frenzy of acquisitions further dampened Entain’s reputation and the operator subsequently committed to a major turnaround effort to cut costs and return its digital business to growth.