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“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.
“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.
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Prediction markets aside, the absence of crypto on a federal level may have some drag on the regulated industry, especially in the iGaming and sports betting space.
Younger patrons are increasingly familiar with crypto, but the lack of regulatory adoption in the regulated space can push bettors to offshore or unlicensed platforms, most of which do accept it. At the ICE Barcelona conference in 2025, a panel of international sports betting CEOs lamented the fact that they were barred from adopting crypto, while their black-market competitors were not.
A report released in June by payment provider Paysafe said the percentage of online sports bettors who dabble in crypto is 64%, more than double the US average of 30%. Crypto deposits are only legal in two states, Wyoming and Colorado, but crypto withdrawals are not legal anywhere – 85% of respondents said they would welcome withdrawals as an option, Paysafe said.
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Touch Sokhak, deputy spokesperson of the Ministry of Interior, emphasised that the operation seeks to prevent Cambodia from becoming “a safe haven or money-laundering base for technology-related criminals”.
However, the sustained enforcement drive has already taken a toll on the wider Cambodian economy. In May, the government lowered its 2026 GDP growth forecast as construction, real estate and consumer spending absorb the short-term impact of the crackdown.
Meanwhile, the CGMC has not disclosed when the integrity and quality framework will be finalised, leaving casino operators without concrete guidance on the new requirements.