Monsters Unchained

What is Monsters Unchained?

The report also cites brands targeting a specifically banned vertical or product within a jurisdiction as driving black market activity. While markets across Europe have many examples, one such flagged in the report is that iGaming remains illegal for licensed operators in France.

“The largest black market operators have scaled to create recognisable brands with traffic that can compare to domestically licensed operators,” the report’s authors wrote. “The top group of sites by common owner has a 12% share of traffic, while the largest single brand has 10%.”

Beyond offering crypto payment solutions, a number of black market operators are licensed in “light touch” offshore jurisidictions which use opaque offshore operating structures to help to obscure company ownership and make local enforcement against these companies complex, the report noted.

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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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Of the KSA’s update, Fuchs said: “If you [as an operator] have a clean sheet, there are some hoops, but for various modules you can just send a declaration which states that you’re compliant.”

He emphasised the new system would make burdens less demanding than before, but the new ‘exit plan’ requirement and sharper duty‑of‑care definitions do bring some added complexity.

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