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Compared to the 2021 licensing round, the KSA adopted a more granular and stringent approach to its licence renewal process. This was expected following new policy rules set out by the regulator in September 2025.

One such rule was for licensees that had faced compliance enforcement during the five years operating in the Netherlands.

At the time KSA announced: “Providers that made mistakes in the past five years must explain during the application process how they have learned from previous mistakes and how they intend to prevent recurrence. If we find this explanation insufficient, the permit may be denied or additional conditions and restrictions may be imposed.” 

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According to the arrest warrant affidavit, law enforcement began investigating Pietras after an employee with a third-party company that assists funeral homes in managing and administering funeral contracts notified police about possible discrepancies at Pietras Family Funeral Homes in Coventry. Such funeral trust administrators partner with funeral homes to provide various programs, including trust funds, insurance policies, and escrow account management.

Law enforcement investigators uncovered a mountain of alleged theft. As the news spread, clients began requesting escrow statements, only to find that their funds were never deposited.

Prosecutors alleged that Pietras was stealing the funeral money to fund his gambling addiction. Law enforcement found that Pietras made more than 800 casino trips over a 14-year period.

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Notably, the Spectrum report does acknowledge that Evolution did not knowingly allow games in prohibited territories, however, it has also flagged a number of compliance issues, which resulted in its games being provided in markets where online gambling is, or has been, prohibited.

Here are some of the dossier’s key findings, some of which raise questions around Evolution’s compliance operations during the period assessed.

Within the initial pages of its lengthy August 2021 report, Spectrum Gaming explains it carried out an extensive technical, operational and compliance review of Evolution’s “business practices, public record database research and an assessment of the company’s anti-money laundering compliance procedures and processes, as they related to the allegations contained in the ‘anonymous report'”.