Evolution Narrowly Avoided UK License Suspension

Britain’s Gambling Commission considered suspending Evolution’s license after its games appeared on unlicensed gambling sites. The regulator ultimately stopped short of that step after the supplier acted on the findings.

The license review began in December 2024. The Commission had identified what appeared to be five Evolution games on six unlicensed websites in August and later asked the supplier to verify them. The sites were operated by two third-party businesses. The Commission said they received large volumes of visits from UK consumers between December 2023 and November 2024.

Review Exposed Weak Supply-Chain Checks

Evolution confirmed that the games were legitimate and proceeded to block access from Great Britain and terminate their relationship with the two operators. The move solved the immediate problem but did not resolve the larger issue of compliance.

The investigators reviewed the methods used by Evolution to assess businesses further down its distribution chain. They concluded that the controls did not sufficiently address the risk from the unlicensed operators and sub-licensees.

Risk Assessment Fell Behind the Market

The Commission found that Evolution’s anti-money laundering assessment was inappropriate from April 2024 to January 2025. This is because the company had failed to adequately consider the distribution of its products by third parties. Its AML policies also lacked detail on due diligence and ongoing monitoring of sub-licensees, including enhanced measures for higher-risk relationships. The Commission said it was unclear which risk-based checks Evolution carried out.

There was a discrepancy between the controls that were put in place and the supply of Evolution’s products. These deficiencies have been noted under License Conditions 12.1.1 and 12.1.2. The Commission has also pointed out deficiencies in relation to risk assessment, due diligence, and internal controls of the 2017 Money Laundering Regulations.

John Pierce, the Commission’s director of enforcement, stated that the failings were serious enough for the Commission to consider suspending the license.

Cooperation Kept the License in Place

The Commission did not suspend the license. It noted that Evolution had responded quickly, fully cooperated with the investigation and accepted the failings at an early stage. Subsequent testing did not identify any further instances of concern.

Evolution agreed to pay £4.75 million in lieu of a financial penalty. The company will also be responsible for some of the investigation costs of the Commission.

A new condition has been included in its UK operating license. Evolution is required to arrange an independent audit of its relevant policies, procedures, and controls within 12 months of the conclusion of the license review.

The supplier said the two operators had breached its terms of supply and actively evaded the restrictions in place. It stated that both business connections were terminated once the access issue in the UK became known.

Distribution Risk Moves up the Agenda

The case shows that the Commission expects suppliers to know who receives their games, where the content can be accessed and whether controls remain effective after distribution. Contractual restrictions and technical blocks were not enough on their own. The regulator found that Evolution’s monitoring had failed to identify how its games were reaching the unlicensed sites.

That point will concern other B2B providers with several layers of resellers, aggregators and sub-licensees. The regulatory risk now sits in the full distribution chain, including parts that suppliers may not control directly.