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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.
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.
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As well as a statewide exclusion register, the package also set out to reduce the number of poker machines from the current figure of 87,000 across 2,100 clubs and hotels.
The government said it aims to achieve this by increasing the forfeiture rate when gaming machine entitlements are traded from one in three to one in two.
The NSW government initiated its first formal review of ClubGRANTS in over a decade after taking office in 2023. Although the final report was submitted in January 2025, it has yet to be released publicly.
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Two blockbuster developments in the casino space earlier this year seemed to indicate an increasingly bullish bet on the sector, including Fertitta Entertainment’s acquisition of Caesars Entertainment in May. The other is a subsequent takeover offer of MGM Resorts from its largest shareholder, Barry Diller’s People Inc. But a negative shift in market conditions could affect both deals.
In July, Fertitta’s General Counsel Steven Scheinthal told the Nevada Gaming Control Board that the company had a letter of intent from banks to finance the transaction but was waiting for better borrowing conditions. Fertitta is assuming nearly $12 billion in Caesars’ debt and is committed to a $6.6 billion financing package.
“Our hope is that in the next few months there will be a window of opportunity where the market will be hotter and [it’s] a more interest rate friendly environment where we can go raise the money and then just put it in an escrow account,” Scheinthal said at the time.
