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The report identifies land-based and online casinos and sports betting as carrying the highest money laundering exposure. By contrast, lotteries and scratchcards present lower risk.
It finds that online gaming shows more documented terrorist financing activity than gambling, although proliferation financing risks remain limited across both sectors.
Cash, e-wallets, mobile money and virtual assets emerge as the payment methods most vulnerable to abuse. This is particularly true where operators use them to structure deposits below reporting thresholds.
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“Evolution may be unwittingly susceptible to having its games played through third-party operators, in violation of its contracts…”
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.
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The law came at the request of Full House Resorts, the Las Vegas-based regional gaming operator that expressed interest in relocating its Rising Star Casino in Rising Sun to a more attractive market, specifically in the northeastern part of the state.
During the lawmaking process, Full House’s exclusivity was stripped in favor of welcoming any company currently licensed as a commercial casino in the US to bid on the possible license. Lawmakers also threw in a one-time $150 million fee for the concession and a mandatory investment minimum of $500 million, all but ending Full House’s interest.
“The bill changed many times. We make money in Rising Sun. We always have, not a lot of money, but we make money. We continue to make money in Rising Sun. And we will continue to do that for our shareholders, as well as for the good of the state,” Full House CEO Daniel Lee said in March.