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Compared to the 2021 licensing round, the KSA adopted a more granular and stringent approach to its licence renewal process. This was expected following new policy rules set out by the regulator in September 2025.

One such rule was for licensees that had faced compliance enforcement during the five years operating in the Netherlands.

At the time KSA announced: “Providers that made mistakes in the past five years must explain during the application process how they have learned from previous mistakes and how they intend to prevent recurrence. If we find this explanation insufficient, the permit may be denied or additional conditions and restrictions may be imposed.” 

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“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.

Within its investigation Black Cube named a number of Evolution employees which it had interviewed and reported to have provided information on the company that supported the intelligence firm’s claims.

An interview carried out by Black Cube with CEO of games developer Ezugi Kfir Kugler had allegedly confirmed that Evolution knowingly provided games in markets sanctioned by the New Jersey Division of Gaming Enforcement.